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Lenair Moses v. United States

Paid petition · United States Court of Appeals for the Fourth Circuit, No. 21-4067 · judgment January 19, 2022


Certiorari denied · January 9, 2023
Pre-decision estimate: 8% cert probability (95% interval 5%–13%)

Before the decision, about 1.9× the 4.1% base rate. The model weighted this up for counsel with five or more prior petitions here, a circuit split argued in the petition, and a dissent in the court below (flagged in the petition).

Questions presented

In Stinson v. United States, 508 U.S. 36 (1993), this Court held that Seminole Rock deference, now generally known as Auer deference, applies to interpretive or explanatory commentary in the U.S. Sentencing Guidelines Manual. Id. at 38. In Kisor v. Wilkie, 139 S. Ct. 2400 (2019), this Court clarified the limits on this deference, and made clear that courts may extend Auer or Seminole Rock deference only where the law remains “genuinely ambiguous” after the court has “exhausted all the traditional tools of construction.” Id. at 2415 (quotation marks omitted). The circuits are deeply divided over whether Kisor’s holding applies in the Guidelines context. The questions presented are:

  1. Whether the limits on agency deference announced in Kisor constrain the deference that courts may accord to the commentary to the Sentencing Guidelines.

  2. Whether deference to the Guidelines commentary is impermissible in any form. (i)

Counsel of record

For petitioner
Catherine Emily Stetson
Hogan Lovells US LLP

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 2 conferences

Amicus briefs
1 cert-stage

Linked docket
21A700

Proceedings

  1. Jan 09 2023
    Motion for leave to file amicus brief filed by Cato Institute GRANTED.
  2. Jan 09 2023
    Petition DENIED.
  3. Dec 09 2022
    Reply of petitioner Lenair Moses filed. (Distributed)
  4. Dec 07 2022
    DISTRIBUTED for Conference of 1/6/2023.
  5. Nov 21 2022
    Brief of respondent United States in opposition filed.
  6. Oct 20 2022
    Brief amicus curiae of New Civil Liberties Alliance filed.
  7. Oct 14 2022
    Motion to extend the time to file a response is granted and the time is extended to and including November 21, 2022.
  8. Oct 13 2022
    Motion to extend the time to file a response from October 20, 2022 to November 21, 2022, submitted to The Clerk.
  9. Sep 20 2022
    Response Requested. (Due October 20, 2022)
  10. Sep 19 2022
    Motion for leave to file amicus brief filed by Cato Institute.
  11. Sep 14 2022
    DISTRIBUTED for Conference of 10/7/2022.
  12. Sep 07 2022
    Waiver of right of respondent United States to respond filed.
  13. Aug 19 2022
    Petition for a writ of certiorari filed. (Response due September 22, 2022)
  14. May 11 2022
    Application (21A700) granted by The Chief Justice extending the time to file until August 20, 2022.
  15. May 06 2022
    Application (21A700) to extend the time to file a petition for a writ of certiorari from June 21, 2022 to August 20, 2022, submitted to The Chief Justice.