Case Citator › Michael Turner v. Warden Coleman FCI (Medium)

Michael Turner v. Warden Coleman FCI (Medium)

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

Abrogated
Court
Eleventh Circuit
Citation
709 F.3d 1328
Decided
Confirmed treatments
2
Flagged citations read
81 of 81
Citing cases (total)
178
Treatment dates
2015–2022
Abrogated
A reviewed court treats this case as abrogated by later authority. Michael Turner v. Warden Coleman FCI (Medium) has been abrogated in part: all 81 flagged citations have been read, and the 2 confirmed treatments are listed below. Johnson v. United States invalidated the ACCA residual clause, displacing Turner's residual-clause holdings for shooting into a building and battery on a law-enforcement officer; United States v. Hill expressly recognized that result.
More on how this was screened

Chappelle v. Warden later questioned whether Borden v. United States also undermined Turner's Florida-aggravated-assault holding, but subsequent Eleventh Circuit decisions continued to treat that offense and Florida aggravated battery as violent felonies under the elements clause. The remaining citing opinions applied those surviving holdings, rejected challenges to Turner, or repeated history parentheticals reporting Johnson's act.

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.

178 later cases cite Michael Turner v. Warden Coleman FCI (Medium); 81 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 Michael Turner v. Warden Coleman FCI (Medium)?

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

Abrogated

  • The Supreme Court invalidated the ACCA residual clause on which Turner relied to classify shooting into a building and battery on a law-enforcement officer as violent felonies.

    Johnson v. United States · Supreme Court of the United States · filed

    We hold that imposing an increased sentence under the residual clause of the Armed Career Criminal Act violates the Constitution's guarantee of due process.
    Read the full opinion on CourtListener →

Questioned

  • The district court questioned whether Borden undermined Turner's holding that Florida aggravated assault is an ACCA violent felony if the offense could be committed recklessly, while leaving the issue undecided.

    Chappelle v. Warden · W.D. Va. · filed

    After Borden, then, it appears that Turner may not be good law.
    Read the full opinion on CourtListener →

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