Johnson v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: June 26, 2015
  • Case #: 13-7120
  • Judge(s)/Court Below: Scalia, J., delivered the opinion of the Court, in which Roberts, C.J., and Ginsburg, Breyer, Sotomayor, and Kagan, JJ., joined. Kennedy, J., and Thomas, J., filed opinions concurring in the judgment. Alito, J., filed a dissenting opinion.
  • Full Text Opinion

Imposing an increased sentence under the Armed Career Criminal Act's residual clause violates due process.

After Petitioner pled guilty to being a felon in possession of a firearm, the United States sought an enhanced sentence under the residual clause of the Armed Career Criminal Act (ACCA). The Act imposes an increased prison term upon a defendant with three prior “violent felony” convictions. The District Court upheld the increased sentence and the Eighth Circuit affirmed. The Supreme Court granted certiorari to decide whether an unlawful possession of a short-barreled shotgun ranks as a violent felony under the residual clause. The Court later asked the parties to present re-argument to address the compatibility of the residual clause with the Constitution’s prohibition of vague criminal laws.

The Court held criminal statutes that define elements of a crime or that provide fixed sentences may not be vague. The residual clause is unconstitutionally vague because of the uncertainty about how to measure the risk of a crime and how much risk is required for a crime to qualify as a violent felony. The indeterminacy of the residual clause of the ACCA denies fair notice to defendants. Imposing an increased sentence under the residual clause of the Armed Career Criminal Act violates the Constitutional guaranty of due process. The Court reversed and remanded the case for further proceedings consistent with this opinion.

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