[1] Samuel James Johnson was a lifelong criminal and active white supremacist who, starting in 2010, was monitored by the FBI due to his involvement in suspected terrorist groups.
Johnson pleaded guilty to the weapons charges and was sentenced under the ACCA's residual clause to a statutory minimum of 15 years for having three prior "violent felony" convictions, one of which was possession of a sawed-off shotgun.
He declared that individuals are unconstitutionally deprived of due process when they are convicted under "a criminal law so vague that it fails to give ordinary people fair notice of the conduct it punishes.
"[2]: 14 Noting that "[d]ecisions under the residual clause have proved to be anything but evenhanded, predictable, or consistent",[2]: 15 the Court decided that "[s]tanding by James and Sykes would undermine, rather than promote, the goals that stare decisis is meant to serve.
He also found the circumstances of Johnson's sawed-off shotgun conviction, it being in his possession during a drug deal in a public parking lot, could have met even a narrow interpretation of the clause.