| Logan v. United States | |
|---|---|
 | |
| Argued October 30, 2007 Decided December 4, 2007 | |
| Full case name | Logan v. United States |
| Docket no. | 06-6911 |
| Citations | 552 U.S. 23 ( more ) 128 S. Ct. 475; 169 L. Ed. 2d 432 |
| Case history | |
| Prior | United States v. Logan, 453 F.3d 804 (7th Cir. 2006) |
| Court membership | |
| |
| Case opinion | |
| Majority | Ginsburg, joined by unanimous |
Logan v. United States, 552 U.S. 23 (2007), was a case before the United States Supreme Court.
Defendant pleaded that his sentence (for being a felon in possession of a firearm) was improperly enhanced under the Armed Career Criminal Act of 1984, 18 U.S.C.S. § 921(a)(20), because it was based on prior convictions which did not result in the loss of civil rights. Since that law did not include prior convictions for sentencing purposes if civil rights were restored, defendant argued that it also operated to preclude his prior state battery convictions from consideration at sentencing because the offenses occasioned no loss of civil rights.
The U.S. Court of Appeals for the Seventh Circuit affirmed his sentence. [1]
Is a conviction that does not result in a loss of civil rights excluded from the "three convictions rule" that are required to activate the Armed Career Criminal Act's sentence enhancement? [2]
The Court unanimously held that the "civil rights restored" exemption of convictions for sentence-enhancement purposes did not extend to a defendant who retained his civil rights at all times, and whose postconviction legal status remained in all respects unaltered by any state dispensation. Justice Ruth Ginsburg wrote the opinion of the Supreme Court. [2] Restoration of rights means that the rights were previously taken away, and rights retained were not functionally equivalent to rights revoked but later restored. Further, the other statutory basis for disregarding convictions involved convictions which were expunged or set aside, or for which the offender was pardoned, all of which were postconviction events which relieved consequences of the convictions, and there was no showing of any congressional intent to broaden the "civil rights restored" exemption to cover convictions attended by no loss of civil rights.
United States v. Dominguez Benitez, 542 U.S. 74 (2004), was a United States Supreme Court case in which the Court ruled that, in a criminal proceeding in federal court, a defendant who does not alert the district court to a possible violation of Rule 11 of the Federal Rules of Criminal Procedure must show on appeal that the violation affirmatively affected his rights in order to obtain reversal of his conviction by guilty plea. Rule 11, which pertains to criminal prosecutions in United States federal courts only, governs the offering of plea bargains to criminal defendants and the procedures district courts must employ to ensure that the defendant knows of and properly waives his trial-related constitutional rights.
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Rummel v. Estelle, 445 U.S. 263 (1980), was a United States Supreme Court case in which the Court upheld a life sentence with the possibility of parole under Texas' three strikes law for a felony fraud crime, where the offense and the defendant's two prior offenses involved approximately $230 of fraudulent activity.
Barr v. City of Columbia, 378 U.S. 146 (1964), is a United States Supreme Court decision that reversed the breach of peace and criminal trespass convictions of five African Americans who were refused service at a lunch counter of a department store. The Court held that there was insufficient evidence to support the breach of peace convictions, and reversed the criminal trespass convictions for the reasons stated in another case that was decided that same day, Bouie v. City of Columbia, which held that the retroactive application of an expanded construction of a criminal statute was barred by due process of ex post facto laws.
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Descamps v. United States, 570 U.S. 254 (2013), was a case in which the United States Supreme Court clarified standards for evaluating potential prior offenses under the Armed Career Criminal Act (ACCA). In an 8–1 decision written by Justice Elena Kagan, the Supreme Court held that judges may only look at the statutory elements of a crime, rather than the facts associated with that particular crime, "when the crime of which the defendant was convicted has a single, indivisible set of elements." In his review of the case for SCOTUSblog, Daniel Richman opined that following the Court's decision, "[w]hether or not a prior conviction is going to 'count' will have to be determined as mechanically as possible."
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.
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.
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