Andres Mencia, a former physician, was convicted of conspiracy to dispense controlled substances without a legitimate medical purpose. After the Supreme Court remanded the case and the Eleventh Circuit affirmed the conviction, the mandate issued on February 1, 2023. More than a year later, in November 2024, Mencia filed a motion to vacate his sentence under 28 U.S.C. § 2255. He argued that his motion was timely because two legal developments—the Supreme Court's 2022 decision in Ruan v. United States and the Eleventh Circuit's 2023 decision in United States v. Duldulao—constituted intervening changes in law that should restart the one-year statute of limitations. The district court denied the motion as untimely and, alternatively, on the merits, but failed to specifically address Mencia's argument regarding the intervening changes in law. This procedural omission raised a question under Clisby v. Jones, which generally requires district courts to resolve all constitutional claims to ensure a full record for appellate review.
The Eleventh Circuit addressed whether the district court's failure to address Mencia's timeliness argument required a remand. While acknowledging that a district court must resolve all constitutional claims to ensure a full record, the court explained that a remand is unnecessary when the petitioner's argument fails as a matter of law. The core of Mencia's argument relied on 28 U.S.C. § 2255(f)(3), which allows the one-year limitations period to restart if the Supreme Court recognizes a new right and makes it retroactively applicable. The court rejected Mencia's reliance on Ruan v. United States because the Supreme Court decided Ruan in 2022, which was before Mencia's conviction became final in 2023. The court held that a Supreme Court decision issued before a conviction becomes final cannot serve as a change in law to restart the limitations period. Furthermore, the court rejected the reliance on United States v. Duldulao, noting that it was a decision from the Eleventh Circuit, not the Supreme Court. Under the plain text of section 2255(f)(3), only Supreme Court decisions can restart the limitations period. Consequently, Mencia's timeliness argument failed as a matter of law, rendering the district court's procedural error harmless.
The decision affirms the denial of Mencia's motion, leaving his conviction and sentence in place. It clarifies that the statute of limitations for § 2255 motions cannot be restarted by Supreme Court decisions issued prior to a conviction becoming final, nor by circuit court decisions. The ruling limits the ability of prisoners to use intervening case law to bypass the one-year filing deadline unless the Supreme Court explicitly recognizes a new right after the conviction is final. No remand was ordered because the legal argument was meritless.