Should a COA issue because reasonable jurists could conclude that Johnson's interpretation of the ACCA's residual clause triggers a Townsend claim against the residual clause of the advisory career offender guideline, given Beckles's acknowledgment that Townsend claims survived its narrow vagueness holding, or because this issue is important enough to justify percolation in the circuit courts?

QUESTION PRESENTED 1. Townsend v. Burke, 334 U.S. 736, 740-741 (1948), held that a sentence violates due process when it is tainted by “misinformation” and “false information” about recidivism’s severity. Johnson v. United States, 1385 8.Ct. 2551 (2015), held the Armed Career Criminal Act’s residual clause, 18 U.S.C. §924(e)(2)(B)(ii), void for vagueness because it wasn’t capable of sensible construction. Beckles v. United States, 137 S.Ct. 886 (2017), held the advisory guidelines immune from the void-forvagueness doctrine, but emphasized they were not immune from a Townsend misinformation claim (id. at 896), and did not displace the uniform and well-settled practice of applying constructions of the ACCA to identical Guidelines. Here, the district court ruled that Beckles foreclosed relying on Johnson’s interpretation of the ACCA’s residual clause to raise a Townsend claim against the residual clause of the advisory career offender guideline, USSG §4B1.2(a)(2) (2005). And, to the point of this petition, both the district court and the Ninth Circuit denied a certificate of appealability on petitioner James Troiano’s Johnson-Townsend claim. The question presented is: Should a COA issue because reasonable jurists could conclude that Johnson’s interpretation of the ACCA’s residual clause triggers a Townsend claim against the residual clause of the advisory career offender guideline, given Beckles’s acknowledgment that Townsend claims survived its narrow vagueness holding, or because this issue is important enough to justify percolation in the circuit courts?