Hollis v. United States of America

Mark Hollis filed a motion to vacate, set aside, or correct his federal sentence under 28 U.S.C. § 2255, challenging the enhanced penalty imposed under the Armed Career Criminal Act (ACCA). Hollis argued that his prior state convictions no longer qualified as predicate violent felonies following the Supreme Court's decision in Johnson v. United States, which struck down the ACCA's residual clause as unconstitutionally vague. The United States District Court denied his motion, and the Sixth Circuit Court of Appeals affirmed. Hollis subsequently petitioned the Supreme Court for a writ of certiorari. On November 19, 2018, the Supreme Court denied his petition, declining to review the case. The denial effectively left intact his enhanced sentence under the ACCA.

The Supreme Court of the United States denied the petition for a writ of certiorari on November 19, 2018, declining to hear the case. The lower court rulings denying Hollis's motion to vacate his sentence were thus left undisturbed.

Whether Hollis's prior state convictions constitute valid predicate offenses under the Armed Career Criminal Act after the residual clause was invalidated in Johnson v. United States, and whether the district court properly denied his § 2255 motion to vacate his enhanced sentence.

The denial of certiorari in Hollis v. United States reflects the Supreme Court's continued reluctance to further narrow the scope of the Armed Career Criminal Act beyond its landmark decision in Johnson. The case highlights ongoing post-conviction litigation by federal inmates seeking sentence reductions based on constitutional challenges to sentencing enhancements. It also underscores the procedural barriers faced by § 2255 movants, particularly regarding the timeliness and substantive merit of claims relying on newly recognized constitutional rules. While not establishing new precedent, the case contributes to the broader legal landscape of ACCA interpretation and federal habeas corpus litigation.