Case Citator › Mathis v. United States

Mathis v. United States

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
579 U.S. 500
Decided
Confirmed treatments
3
Flagged citations read
311 of 311
Citing cases (total)
2,746
Treatment dates
2018–2019
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Mathis v. United States has been limited in three later opinions, and all 311 flagged citations have been read. Richards v. Kallis, United States v. Lewis, and Dennis v. Upton held that Mathis was unavailable retroactively or at a particular stage of collateral review.
More on how this was screened

Most other opinions applied Mathis's elements-versus-means framework or described its effect on earlier cases; those opinions did not adversely treat Mathis.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

2,746 later cases cite Mathis v. United States; 311 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Mathis v. United States?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The district court held that Mathis was not retroactive for the petitioner's collateral challenge.

    Richards v. Kallis · United States District Court for the Northern District of West Virginia · filed

    The magistrate judge correctly noted that the cases on which petitioner relies, Mathis and Hinkle, do not meet this requirement because neither are retroactive.
    Read the full opinion on CourtListener →

  • The Tenth Circuit limited Mathis's use in Johnson collateral review to the harmless-error stage and declined to apply it when deciding whether a Johnson error existed at the historical stage.

    United States v. Lewis · United States Court of Appeals for the Tenth Circuit · filed

    Mathis and other current, post-sentence cases are only applicable at the harmless error stage of review, once the movant has established the existence of a Johnson error. ... Petitioner was sentenced in 2010. Mathis was decided in 2016. Because Mathis is a “post-sentencing decision” that was not part of the “controlling law . . . at the time of sentencing,” we do not apply it on collateral review at this stage of the analysis.
    Read the full opinion on CourtListener →

  • The district court held that Mathis was not retroactively applicable on collateral review and could not support a savings-clause petition.

    Dennis v. Upton · United States District Court for the Northern District of Texas, Fort Worth Division · filed

    Although Dennis cites to these decisions, she has not shown that they have been made retroactively applicable, and/or that any of the decisions establishes that she was actually innocent of the charge against her because the conduct for which she was convicted has been decriminalized. See generally Christopher, 342 F.3d at 382. The Fifth Circuit has determined that neither Mathis nor Descamps announced a new rule on constitutional law that has been made retroactive on collateral review.
    Read the full opinion on CourtListener →

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