USA v. Michael Shane Ragland
Split Score
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Case Summary
Disposition
Vacated
The Eleventh Circuit granted Michael Shane Ragland’s petition for rehearing, vacated his 173-year sentence, and remanded for resentencing under the First Step Act in light of the Supreme Court’s decision in Hewitt v. United States, which overruled the circuit’s prior interpretation of § 403 of the Act. The court, however, reaffirmed that district courts lack subject-matter jurisdiction to entertain new, uncertified claims in a successive § 2255 motion, thereby rejecting the broader amendment approach adopted by the Fourth and Seventh Circuits.
Circuit Split Identified
Legal Issue
Whether a district court may, under Federal Rule of Civil Procedure 15, allow a prisoner to add new claims to a successive 28 U.S.C. § 2255 motion without prior appellate certification.
Circuit Positions
District courts lack jurisdiction to consider uncertified claims in a successive § 2255 motion; Rule 15 cannot expand the scope beyond what the court of appeals authorized.
District courts may permit amendments to add new claims to a successive § 2255 motion under Rule 15 without additional appellate authorization.
Conflict Summary
The Eleventh Circuit holds that district courts lack subject-matter jurisdiction to consider additional § 2255 claims that were not expressly authorized by the court of appeals, whereas the Fourth and Seventh Circuits allow prisoners to amend successive § 2255 motions under Rule 15 without further appellate gatekeeping.