Decisions by the United States Supreme Court are sometimes one-off\u00a0affairs, resolving a specific issue that definitively settles the law on that point\u00a0going forward. Sometimes the Court tells us this is the case, for instance, lim-iting its reasoning to the decision at hand.1 Other times, the nature of the issue\u00a0clearly demonstrates it is of limited or no prospective importance outside the\u00a0narrow context in which it was issued.\u00a0Alternatively, an initial decision by the Court will set off a flurry of activ-ity, bouncing an issue between the Supreme Court and the courts of appeals.\u00a0This may be necessary to resolve different interpretive facets of a single stat-utory provision. For example, the Court\u2019s decision in Moncrieffe v. Holder,\u00a0which concerned the aggravated felony drug trafficking provision in the\u00a0Immigration and Nationality Act (\u201cINA\u201d),3 concluded a seven-year span of\u00a0Supreme Court litigation entailing three separate decisions.4 Or it may be to\u00a0resolve how an ostensibly definitive interpretation applies upon different\u00a0practical applications, including how to apply the Armed Career Criminal\u00a0Act\u2019s \u201cresidual clause\u201d to a range of different predicate offenses.5 And of\u00a0course that enterprise itself ended with a definitive judgment, of sorts, with\u00a0the Supreme Court finally holding that \u201cresidual clause\u201d to be unconstitution-ally vague,6 igniting a chain of vagueness litigation centered on other simi-
\nlarly worded provisions in the federal statutes.\u00a0The Supreme Court\u2019s recent decision in Pereira v. Sessions seemed like a\u00a0case destined for the former category of narrow, limited holdings.8 The issue<\/p>\n