Goodridge v. United States
- Denise Cote
- 1:16-cv-04477
- U.S. District Court · Southern District of New York
- 2
In Goodridge v. United States, Judge Cote granted Goodridge’s petition and vacated his firearm conviction after Davis invalidated the governing provision.
Mark Goodridge, whose federal firearm conviction was vacated.
What happened
In Goodridge v. United States, Mark Goodridge had pleaded guilty to possessing a firearm in furtherance of a crime of violence and received a 60-month prison sentence. The underlying crime was conspiracy to commit Hobbs Act robbery.
Goodridge later asked the court to set aside his conviction under a federal law allowing challenges to unlawful sentences. He relied mainly on the Supreme Court’s decision in Johnson. The court initially denied his petition, but the Supreme Court later held in Davis that the firearm provision used in Goodridge’s case was unconstitutionally vague.
After the Second Circuit sent the case back, both sides agreed that Goodridge’s conviction had to be vacated and that no further proceedings were needed. Judge Denise Cote granted the petition and vacated Goodridge’s conviction under 18 U.S.C. § 924(c)(1)(A).
The detailed version
- Goodridge v. United States · No. 1:16-cv-04477
- Denise Cote
- Apr. 6, 2021
Background
Mark Goodridge pleaded guilty on January 31, 2013, to one count of possessing a firearm in furtherance of a crime of violence, violating 18 U.S.C. § 924(c)(1)(A). The crime serving as the basis for that conviction was conspiracy to commit Hobbs Act robbery. He was sentenced to 60 months’ imprisonment.
Earlier Proceedings
On June 13, 2016, Goodridge filed a petition under 28 U.S.C. § 2255, which allows a federal prisoner to ask the sentencing court to vacate, set aside, or correct a sentence. He principally argued that his conviction was invalid after the Supreme Court’s decision in Johnson v. United States. On August 25, 2016, the court denied the petition because then-controlling Second Circuit precedent held that Johnson’s reasoning did not apply to Goodridge’s case.
Goodridge appealed. While that appeal was pending, the Supreme Court decided United States v. Davis and held that the provision under which Goodridge was convicted was unconstitutionally vague. On January 20, 2021, the Second Circuit vacated the 2016 order in light of Davis and another decision, United States v. Barrett, and sent the matter back for further proceedings.
Ruling
The parties agreed that Goodridge’s conviction had to be vacated and that no further proceedings were required. Judge Denise Cote granted Goodridge’s June 13, 2016 petition to vacate his conviction and sentence under § 2255. The court vacated his January 31, 2013 conviction for possessing a firearm in furtherance of a crime of violence under § 924(c)(1)(A).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.