In Re: Wayne Anderson

Wayne Anderson was sentenced based on United States Sentencing Guideline § 4B1.2, which contains the same 13 words that Johnson v. United States, 576 U.S. -, 135 S.Ct. 2551, 192 L.Ed.2d 569 (2015), made unconstitutional. The government agrees that Johnson invalidated the identical language of USSG § 4B1.2, at least on direct appeal. But our court ruled otherwise. See United States v. Matchett, 802 F.3d 1185 (11th Cir. 2015). I have written before that I believe “Matchett was wrongly decided.” In re Robinson, 822 F.3d 1196, 1198 n. 2 (11th Cir. 2016) (Martin, J., concurring). I. later…