In the United States, habitual offender laws have been implemented since at least 1952, and are part of the United States Justice Department's Anti-Violence Strategy. These laws require a person who is convicted of an offense and who has one or two other previous serious convictions to serve a mandatory life sentence in prison, with or without parole depending on the jurisdiction. The purpose of the laws is to drastically increase the punishment of those who continue to commit offenses after being convicted of one or two serious crimes.
Ewing v. California, 538 U.S. 11 (2003), is one of two cases upholding a sentence imposed under California's three strikes law against a challenge that it constituted cruel and unusual punishment in violation of the Eighth Amendment. As in its prior decision in Harmelin v. Michigan, the United States Supreme Court could not agree on the precise reasoning to uphold the sentence. But, with the decision in Ewing and the companion case Lockyer v. Andrade, the Court effectively foreclosed criminal defendants from arguing that their non-capital sentences were disproportional to the crime they had committed.
Taylor v. United States, 495 U.S. 575 (1990), was a U.S. Supreme Court decision that filled in an important gap in the federal criminal law of sentencing. The federal criminal code does not contain a definition of many crimes, including burglary, the crime at issue in this case. Yet sentencing enhancements applicable to federal crimes allow for the enhancement of a defendant's sentence if he has been convicted of prior felonies. The Court addressed in this case how "burglary" should be defined for purposes of such sentencing enhancements when the federal criminal code contained no definition of "burglary." The approach the Court adopted in this case has guided the lower federal courts in interpreting other provisions of the criminal code that also refer to generic crimes not otherwise defined in federal law.
James v. United States, 550 U.S. 192 (2007), is a decision by the Supreme Court of the United States that held that attempted burglary could serve as a predicate felony under the federal Armed Career Criminal Act (ACCA), which provided that a person convicted of being a felon in possession of a firearm with three prior convictions for either serious drug offenses or violent felonies must be sentenced to a mandatory minimum 15-year prison term.
Begay v. United States, 553 U.S. 137 (2008), is a United States Supreme Court case which held that felony driving while intoxicated is not a "violent felony" for purposes of the Armed Career Criminal Act.
United States v. Rodriquez, 553 U.S. 377 (2008), was a United States Supreme Court case interpreting the Armed Career Criminal Act. Justice Samuel Alito, writing for the 6–3 majority, ruled that although the elements of a crime may not be considered "serious," sentence enhancements related to a defendant's prior record will bear on how the determination is made.
The Armed Career Criminal Act of 1984 (ACCA) is a United States federal law that provides sentence enhancements for felons who commit crimes with firearms if they are convicted of certain crimes three or more times. Pennsylvania Senator Arlen Specter was a key proponent for the legislation.
Sykes v. United States, 564 U.S. 1 (2011), was a case in which the Supreme Court of the United States held that felony vehicle flight, as proscribed by Indiana law, is a violent felony for purposes of the residual clause of the Armed Career Criminal Act (ACCA). Writing for the majority, Justice Kennedy wrote that vehicle flight requires officers to give chase, resulting in more injuries on average than burglary. Dissenting, Justice Scalia criticized the majority for producing an ad hoc judgment based on vague legislation, suggesting they should declare the residual clause of the law unconstitutionally vague. The court would follow that advice several years later in Johnson v. United States and declare the residual clause unconstitutionally vague.
Johnson v. United States, 576 U.S. 591 (2015), was a United States Supreme Court case in which the Court ruled the Residual Clause of the Armed Career Criminal Act was unconstitutionally vague and in violation of due process.
United States v. Antelope, 430 U.S. 641 (1977), was a United States Supreme Court case in which the Court held that American Indians convicted on reservation land were not deprived of the equal protection of the laws; (a) the federal criminal statutes are not based on impermissible racial classifications but on political membership in an Indian tribe or nation; and (b) the challenged statutes do not violate equal protection. Indians or non-Indians can be charged with first-degree murder committed in a federal enclave.
Welch v. United States, 578 U.S. 120 (2016), was a United States Supreme Court case in which the Court ruled that the decision in Johnson v. United States announced a substantive rule change and is therefore retroactive.
Esquivel-Quintana v. Sessions, 581 U.S. ___ (2017), is a case in which the Supreme Court of the United States ruled 8–0 that in the context of statutory rape offenses that criminalize sexual intercourse based solely on the ages of the participants, the generic federal definition of "sexual abuse of a minor" requires the age of the victim to be less than 16. Justice Clarence Thomas delivered the majority opinion.
Sessions v. Dimaya, 584 U.S. 148 (2018), was a United States Supreme Court case in which the Court held that 18 U.S.C. § 16(b), a statute defining certain "aggravated felonies" for immigration purposes, is unconstitutionally vague. The Immigration and Nationality Act (INA) classifies some categories of crimes as "aggravated felonies", and immigrants convicted of those crimes, including those legally present in the United States, are almost certain to be deported. Those categories include "crimes of violence", which are defined by the "elements clause" and the "residual clause". The Court struck down the "residual clause", which classified every felony that, "by its nature, involves a substantial risk" of "physical force against the person or property" as an aggravated felony.
Stokeling v. United States, 586 U.S. ___ (2019), was a United States Supreme Court case in which the court held that state robbery offenses that involve overcoming victim resistance count as "violent felonies" under the definition of that term under the Armed Career Criminal Act of 1984, even when only 'slight force' is required. Under the Armed Career Criminal Act, defendants with three or more violent felonies can face higher sentences when subsequently convicted of a federal firearms-related offense. This case upheld a ruling by the 11th Circuit.
Shular v. United States, 589 U.S. ___ (2020), is an opinion of the United States Supreme Court in which the Court held that, under the Armed Career Criminal Act of 1984, the definition of “serious drug offense” only requires that the state offense involve the conduct specified in the statute. Unlike other provisions of the ACCA, it does not require that state courts develop “generic” version of a crime, which describe the elements of the offense as they are commonly understood, and then compare the crime being charged to that generic version to determine whether the crime qualifies under the ACCA for purposes of penalty enhancement. The decision states that offenses defined under the ACCA are "unlikely names for generic offenses," and are therefore unambiguous. This renders the rule of lenity inapplicable.
Borden v. United States, 593 U.S. ___ (2021), was a United States Supreme Court case involving the classification of prior convictions for "violent felony" in application of Armed Career Criminal Act (ACCA); the ACCA provides for enhanced sentencing for convicted criminals with three or more such felonies in their history. In a 5–4 decision in June 2021, the Supreme Court ruled that crimes resulting from reckless conduct should not be considered as a "violent felony" for the purposes of the ACCA.
Wooden v. United States, 595 U.S. ___ (2022), was a Supreme Court of the United States case dealing with the Armed Career Criminal Act (ACCA). In a unanimous decision, the court ruled that multiple criminal offenses that a person commits during a single criminal episode do not count as separate convictions when considering the number of prior convictions a criminal has under the ACCA.
Bradley Nelson Garcia is an American lawyer and jurist serving as a U.S. circuit judge of the U.S. Court of Appeals for the District of Columbia Circuit. He was an official at the United States Department of Justice from 2022 to 2023.
Brown v. United States,, is a United States Supreme Court case about the Armed Career Criminal Act (ACCA). The Supreme Court affirmed both courts of appeals, holding that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that conviction.
Erlinger v. United States is a case pending before the Supreme Court of the United States. The case may build on the Supreme Court's Sixth Amendment jurisprudence related to the jury right. The case is scheduled for oral argument on January 16, 2024.
