United States of America v. Walker

This appeal presents a single important issue of first impression in this circuit. Can a federal prisoner, by filing a habeas corpus petition pursuant to 28 U.S.C. § 2255, challenge, reopen and reduce his federal sentence, enhanced under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), after one of his three predicate state court convictions has been vacated in a state habeas action? To date, seven of our sister circuits have held or indicated (without expressly deciding) that he can. Unwilling to create a split with such a majority, we also agree that he can.