(CN) – The U.S. Supreme Court handed down two decisions on Tuesday that revived inmate appeals: one by a prisoner challenging his sentence and another from an inmate seeking habeas relief.
In the first case, Chambers v. United States, the justices determined that Illinois’ crime of failing to report for weekend confinement does not constitute a “violent felony” under the Armed Career Criminal Act (ACCA).
The ACCA imposes a mandatory 15-year prison term on any felon caught with a firearm who has three prior convictions for “serious drug offenses” or “a violent felony.”
Deondery Chambers pleaded guilty to unlawfully possessing a firearm, but challenged his 15-year sentence on the basis that one of his prior convictions – for failing to report for weekend confinement – was neither a drug offense nor a violent felony.
“The ‘failure to report’ crime does not satisfy ACCA’s ‘violent felony’ definition,” Justice Breyer wrote. “The government’s argument that a failure to report reveals the offender’s special, strong aversion to penal custody – pointing to 3 state and federal cases over 30 years in which individuals shot at officers attempting to recapture them – is unconvincing.”
The high court reversed rulings for the government and remanded.
In Jimenez v. Quarterman, the justices unanimously determined that state prisoner Carlos Jimenez had not missed the one-year deadline to file a habeas corpus petition.
The case hinged on the statute of limitation established by the Antiterrorism and Effective Death Penalty Act of 1996, which runs from the latest of four dates. In Jimenez’s case, he appealed his burglary conviction from “the date on which the judgment became final.”
Jimenez said the date could be postponed by the state court’s decision to grant him the right to file an out-of-time direct appeal before he petitioned for habeas relief.
The district court disagreed and deemed his habeas petition untimely. The 5th Circuit affirmed.
Justice Thomas, writing for the unanimous court, reversed and remanded. The judgment is not final if a state court “grants a criminal defendant the right to file an out-of-time appeal during collateral review, but before the defendant has first sought federal habeas relief,” Thomas wrote.