Johnson v. United States | |
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Argued November 5, 2014 Reargued April 20, 2015 Decided June 26, 2015 | |
Full case name | Samuel James Johnson, Petitioner v. United States |
Docket no. | 13-7120 |
Citations | 576 U.S. 591 ( more ) 135 S. Ct. 2551; 192 L. Ed. 2d 569 |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | United States v. Johnson, 526 F. App'x 708 (8th Cir. 2013); cert. granted, 572 U.S. 1059(2014). |
Holding | |
The Residual Clause of the Armed Career Criminal Act is unconstitutionally vague and as a result one's due process rights are violated. | |
Court membership | |
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Case opinions | |
Majority | Scalia, joined by Roberts, Ginsburg, Breyer, Sotomayor, Kagan |
Concurrence | Kennedy (in judgment) |
Concurrence | Thomas (in judgment) |
Dissent | Alito |
Laws applied | |
Armed Career Criminal Act 18 U.S.C. § 924(e)(1), U.S. Const. amend. V | |
This case overturned a previous ruling or rulings | |
James v. United States (2007) (in part) & Sykes v. United States (2011) (in part) |
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.
The Armed Career Criminal Act (ACCA) was a part of the Comprehensive Crime Control Act of 1984 that was enacted to impose tougher sentences in illegal firearms cases on defendants who have previously been convicted three or more times for "violent" felonies. 18 U.S.C. § 924(e)(2)(B) defined a "violent felony" as an act that threatens "use of physical force against the person of another," "is burglary, arson, or extortion," "involves use of explosives," or "otherwise involves conduct that presents a serious potential risk of physical injury to another." The last part of this definition became known as the "residual clause". [ citation needed ]
Samuel James Johnson was a lifelong criminal and active white supremacist who, starting in 2010, was monitored by the FBI due to his involvement in suspected terrorist groups. Over the years, he revealed to undercover agents his plans to carry out terrorist attacks, as well as his illegal supply of weapons. In 2012, he was indicted on multiple counts of being a felon in possession of firearms and ammunition. Johnson pleaded guilty to the weapons charges and was sentenced under the ACCA's residual clause to a statutory minimum of 15 years for having three prior "violent felony" convictions, one of which was possession of a sawed-off shotgun. [1]
Johnson's lawyers argued that mere possession of a sawed-off shotgun does not qualify as a "violent felony" as described under the residual clause. In 2013, an appeal to the Eighth Circuit upheld the decision by the District Court to sentence Johnson to 15 years in accordance to the ACCA. [2] The Supreme Court of the United States originally granted the case certiorari to decide if the state law banning possession of a sawed-off shot gun qualified as a "violent felony" under the residual clause. The case was initially argued on November 5, 2014, but the Court asked the parties to reconvene and directly address the question of whether or not the residual clause was unconstitutionally vague. The case was reargued on April 20, 2015. [1]
Justice Scalia wrote the opinion of the Court, which determined the residual clause to be in violation of the Fifth Amendment. Scalia described the statute as a "failed enterprise" that invited "arbitrary enforcement." He declared that individuals are unconstitutionally deprived of due process when they are convicted under "a criminal law so vague that it fails to give ordinary people fair notice of the conduct it punishes." [1]
The Court had raised the specter of unconstitutional vagueness in two prior cases regarding the residual clause— James v. United States and Sykes v. United States —that "honed in on the imprecision of the phrase 'serious potential risk'". [1] : 14 However, "neither opinion evaluated the uncertainty introduced by the need to evaluate the riskiness of an abstract ordinary case of a crime." [1] : 14
Noting that "[d]ecisions under the residual clause have proved to be anything but evenhanded, predictable, or consistent", [1] : 15 the Court decided that "[s]tanding by James and Sykes would undermine, rather than promote, the goals that stare decisis is meant to serve." [1] : 15 The Court held that the residual clause was unconstitutionally vague, overruling the contrary holdings in James and Sykes. [1] : 15
Justices Kennedy and Thomas wrote separate opinions concurring in judgment, but disagreeing that the residual clause of ACCA is unconstitutionally vague. [1]
Justice Alito dissented, arguing that the court could and therefore should interpret the residual clause in a narrower way that meets constitutional standards. He also found the circumstances of Johnson's sawed-off shotgun conviction, it being in his possession during a drug deal in a public parking lot, could have met even a narrow interpretation of the clause. [1]
Previous Supreme Court decisions about the "residual clause" of the Armed Career Criminal Act:
Benton v. Maryland, 395 U.S. 784 (1969), is a Supreme Court of the United States decision concerning double jeopardy. Benton ruled that the Double Jeopardy Clause of the Fifth Amendment applies to the states. In doing so, Benton expressly overruled Palko v. Connecticut.
In American constitutional law, a statute is void for vagueness and unenforceable if it is too vague for the average citizen to understand. This is because constitutionally permissible activity may not be chilled because of a statute's vagueness. There are several reasons a statute may be considered vague; in general, a statute might be void for vagueness when an average citizen cannot generally determine what persons are regulated, what conduct is prohibited, or what punishment may be imposed. For example, criminal laws which do not state explicitly and definitely what conduct is punishable are void for vagueness. A statute is also void for vagueness if a legislature's delegation of authority to judges or administrators is so extensive that it could lead to arbitrary prosecutions. A law can also be "void for vagueness" if it imposes on First Amendment freedom of speech, assembly, or religion.
The term aggravated felony was used in the United States immigration law to refer to a broad category of criminal offenses that carry certain severe consequences for aliens seeking asylum, legal permanent resident status, citizenship, or avoidance of deportation proceedings. Anyone convicted of an aggravated felony and removed from the United States "must remain outside of the United States for twenty consecutive years from the deportation date before he or she is eligible to re-enter the United States." The supreme court ruled 5-4 in Sessions v. Dimaya that the residual clause was unconstitutionally vague limiting the term.
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.
Chambers v. United States, 555 U.S. 122 (2009), was a case in which the Supreme Court of the United States held that failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act.
Daniels v. United States, 531 U.S. 374 (2001), was a decision by the Supreme Court of the United States involving the Armed Career Criminal Act. The Court ruled, in a 5–4 decision, that a defendant sentenced under that Act could not challenge previous convictions on appeal that were used to increase his new sentence.
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.
Noto v. United States, 367 U.S. 290 (1961), was a 1961 United States Supreme Court case that reversed the felony conviction of a lower-echelon official of the Communist Party USA (CPUSA).
Johnson v. United States may refer to the following opinions of the Supreme Court of the United States:
McFadden v. United States, 576 U.S. 186 (2015), was a United States Supreme Court case in which the Court held that section 841 of the Controlled Substances Act requires the government to prove that to be in criminal violation, a defendant must be aware that an analogue defined by the Controlled Substance Analogue Enforcement Act with which he was dealing was a controlled substance.
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.
Beckles v. United States, 580 U.S. ___ (2017), was a case in which the United States Supreme Court evaluated whether the residual clause in the United States Advisory Sentencing Guidelines was unconstitutionally vague.
Sessions v. Dimaya, 584 U.S. ___ (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.