Latest 2 Cases: United States v. Holloway (Criminal Law), Vaughn v. Phoenix House New York, Inc. (Labor & Employment Law)

Rethinking Retroactivity in Light of the Supreme Court’s Jury Unanimity Requirement

MICHAEL C. DORF

In light of the U.S. Supreme Court’s decision Monday in Ramos v. Louisiana, in which it held that the federal Constitution forbids states from convicting defendants except by a unanimous jury, Cornell law professor Michael C. Dorf discusses the Court’s jurisprudence on retroactivity. Dorf highlights some costs and benefits of retroactivity and argues that the Court’s refusal to issue advisory opinions limits its ability to resolve retroactivity questions in a way that responds to all the relevant considerations.

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United States v. Holloway

Docket: 19-1035

Opinion Date: April 24, 2020

Judge: Nardini

Areas of Law: Criminal Law

Holloway sought reduction of his 168-month prison sentence and 10-year term of supervised release under Section 404 of the 2018 First Step Act, 132 Stat. 5194. The district court applied the framework of 18 U.S.C. 3582(c)(2), including U.S.S.G. 1B1.10. Because Holloway was sentenced as a career offender, the district court concluded that his Guidelines range after application of the First Step Act was equivalent to his original Guidelines range, so that Holloway was ineligible for a reduction of his term of imprisonment. The district court did not address supervised release. While his appeal was pending, Holloway completed his prison term and was released from custody. The Second Circuit vacated, holding that Holloway’s appeal was not mooted by his release. Holloway remains eligible for a reduction in his term of supervised release and was eligible for relief under the plain language of the Act: The court had previously sentenced him for an offense covered by the Act, and Holloway was not otherwise barred from relief under the Act’s limitations; 18 U.S.C. 3582(c)(1)(B), rather than section 3582(c)(2), provides the correct framework for consideration of a motion for a reduction of a term of imprisonment under the First Step Act; so U.S.S.G. 1B1.10 does not prevent a district court from considering a First Step Act motion made by a defendant whose new Sentencing Guidelines range is equivalent to his original range.

Vaughn v. Phoenix House New York, Inc.

Docket: 19-517

Opinion Date: April 22, 2020

Judge: Jose A. Cabranes

Areas of Law: Labor & Employment Law

Vaughn sued Phoenix House, a drug treatment facility, under 42 U.S.C. 1983, the Fair Labor Standards Act (FLSA) and the New York Labor Law (NYLL), alleging that he was not paid for work he performed while a patient there. Following a remand, the complaint was dismissed for a second time. The Second Circuit affirmed. The section 1983 claim was untimely. Vaughn was not an employee of Phoenix House within the meaning of the FLSA. The court analyzed the “Glatt” factors, used for assessing unpaid internships, to apply the “primary beneficiary test.” Although Vaughn was not compensated for his work duties, Vaughn received significant benefits from staying at Phoenix House. He was permitted to receive rehabilitation treatment there in lieu of a jail sentence and was provided with food, a place to live, therapy, vocational training, and jobs that kept him busy and off drugs.