United States v. Hammond

While not yet addressed by the D.C. Circuit, other circuit courts have considered whether a § 2255 motion attacking the mandatory Guidelines' residual clause is timely if filed within a year of Johnson . The Third, Fourth, Sixth, Ninth and Tenth Circuits have interpreted Johnson as strictly limited to the ACCA and rejected petitions that, like Hammond's, challenged the mandatory Guidelines' residual clause, as "untimely." See United States v. Blackstone , 903 F.3d 1020, 1028 (9th Cir. 2018) ("As of now, however, Blackstone's motion is untimely."); United States v. Green , 898 F.3d 315, 322-23…