McLaughlin v. United States

Last updated
McLaughlin v. United States
Seal of the United States Supreme Court.svg
Argued March 31, 1986
Decided April 29, 1986
Full case nameLamont Julius McLaughlin, Petitioner v. United States
Citations 476 U.S. 16 ( more )
106 S. Ct. 1677; 90 L. Ed. 2d 15; 1986 U.S. LEXIS 146
Holding
An unloaded handgun is a “dangerous weapon” within the meaning of federal bank robbery laws.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr.  · Byron White
Thurgood Marshall  · Harry Blackmun
Lewis F. Powell Jr.  · William Rehnquist
John P. Stevens  · Sandra Day O'Connor
Case opinions
Majority Stevens, joined by unanimous
Laws applied
18 U.S.C.   § 2113

McLaughlin v. United States, 476 U.S. 16 (1986), was a United States Supreme Court case in which the Court unanimously held that an unloaded handgun is a “dangerous weapon” within the meaning of federal bank robbery laws. [1] Justice John Paul Stevens' brief four-paragraph opinion in McLaughlin has been described by some analysts as "the shortest opinion by the Court in decades." [2]

John Paul Stevens American judge

John Paul Stevens is an American lawyer and jurist who served as an Associate Justice of the United States Supreme Court from 1975 until his retirement in 2010. At the time of his retirement, he was the second-oldest serving justice in the history of the Court, the third-longest serving Supreme Court Justice in history. Stevens was considered to have been on the liberal side of the Court at the time of his retirement.

Contents

Background

Federal bank robbery laws

Federal bank robbery statutes provide enhanced penalties for assaults that occur through the use of a “dangerous weapon” during a bank robbery. [3] Over time, a circuit split emerged where some courts ruled that a gun must be "loaded and operable" to qualify as a "dangerous weapon," [4] while other courts held that an unloaded gun could qualify as a "dangerous weapon." [5] The Supreme Court of the United States granted review in McLaughlin v. United States to resolve this circuit split. [6]

Circuit split

In United States federal courts, a circuit split occurs when two or more different circuit courts of appeals provide conflicting rulings on the same legal issue. The existence of a circuit split is one of the factors that the Supreme Court of the United States considers when deciding whether to grant review of a case. Some scholars suggest that the Supreme Court is more likely to grant review of a case to resolve a circuit split than for any other reason.

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about one hundred to one hundred fifty of the more than seven thousand cases that it is asked to review.

Arrest and trial of Lamont Julius McLaughlin

At approximately 9:30 a.m. on July 26, 1984 Lamont Julius McLaughlin and a companion entered a bank in Baltimore, Maryland wearing stocking masks and gloves. [7] McLaughlin "displayed a dark handgun" and ordered patrons to put their hands up. [7] McLaughlin's companion then jumped over the counter and placed approximately $3,400 in a brown paper bag. [7] When McLaughlin and his companion attempted to leave the bank, they were immediately apprehended by police. [7] Officers seized McLaughlin's gun, but discovered it was not loaded. [7] At trial, McLaughlin pleaded guilty to charges of bank robbery and bank larceny. [8] He was also found guilt of assault during a bank robbery “by the use of a dangerous weapon" based on the district court's determination that the unloaded gun was a "dangerous weapon" within the meaning of federal bank robbery statutes. [9] On appeal, the United States Court of Appeals for the Fourth Circuit affirmed McLaughlin's conviction. [8] McLaughlin appealed again to the Supreme Court of the United States, which granted certiorari on November 4, 1985. [10]

United States Court of Appeals for the Fourth Circuit

The United States Court of Appeals for the Fourth Circuit is a federal court located in Richmond, Virginia, with appellate jurisdiction over the district courts in the following districts:

Opinion of the Court

Writing for a unanimous court, Justice John Paul Stevens provided three reasons why an unloaded gun is a "dangerous weapon" under the federal bank robbery statute. [8] First, Justice Stevens argued that "the law reasonably may presume that such an article is always dangerous even though it may not be armed at a particular time or place." [8] Second, he argued that "the display of a gun instills fear in the average citizen," even if it is not loaded, and "creates an immediate danger that a violent response will ensue." [11] Third, he argued that an unloaded gun "can cause harm when used as a bludgeon." [12]

See also

Related Research Articles

Furman v. Georgia, 408 U.S. 238 (1972), was a criminal case in which the United States Supreme Court struck down all death penalty schemes in the United States in a 5–4 decision, with each member of the majority writing a separate opinion. Following Furman, in order to reinstate the death penalty, states had to at least remove arbitrary and discriminatory effects, to satisfy the Eighth Amendment to the United States Constitution.

Roth v. United States, 354 U.S. 476 (1957), along with its companion case Alberts v. California (1957), was a landmark case before the United States Supreme Court which redefined the Constitutional test for determining what constitutes obscene material unprotected by the First Amendment.

Small v. United States, 544 U.S. 385 (2005), was a decision by the Supreme Court of the United States involving 18 U.S.C. § 922(g)(1), which makes it illegal to possess a gun for individuals previously "convicted in any court" of crimes for which they could have been sentenced to more than one year in prison. The Court ruled, in a five to three decision, that "any court" does not include those in foreign countries. This decision resolved a circuit split on the issue, and reversed the lower ruling of the Third Circuit that the law did apply to foreign convictions.

Dixon v. United States, 548 U.S. 1 (2006), was a United States Supreme Court case concerning the level of proof required to establish the affirmative defense of duress in a federal criminal case.

Watson v. United States, 552 U.S. 74 (2007), is a case decided by the Supreme Court of the United States. The Court had earlier held in Smith v. United States (1993) that the exchange of a gun for drugs constituted "use" of a firearm for purposes of a federal statute imposing penalties for "use" of a firearm "during and in relation to" a drug trafficking crime; in Watson, the court decided that a transaction in the opposite direction does not violate the same statute.

Tafflin v. Levitt, 493 U.S. 455 (1990), was a United States Supreme Court case in which the Court held that state courts have concurrent jurisdiction to decide civil claims brought under the Racketeer Influenced and Corrupt Organizations Act (RICO).

United States v. Stevens, 559 U.S. 460 (2010), was a decision by the Supreme Court of the United States, which ruled that 18 U.S.C. § 48, a federal statute criminalizing the commercial production, sale, or possession of depictions of cruelty to animals, was an unconstitutional abridgment of the First Amendment right to freedom of speech.

Dean v. United States, 556 U.S. 568 (2009), was a decision by the United States Supreme Court upholding a 10 year penalty for the discharge of a firearm during the commission of any violent or drug trafficking crime, against a bank robber whose gun went off accidentally.

McDonald v. Chicago, 561 U.S. 742 (2010), is a landmark decision of the Supreme Court of the United States that found that the right of an individual to "keep and bear arms," as protected under the Second Amendment, is incorporated by the Due Process Clause of the Fourteenth Amendment against the states. The decision cleared up the uncertainty left in the wake of District of Columbia v. Heller as to the scope of gun rights in regard to the states.

Chickasaw Nation v. United States, 534 U.S. 84 (2001), was a case in which the Supreme Court of the United States held that Indian tribes were liable for taxes on gambling operations under 25 U.S.C. §§ 2701–2721.

County of Oneida v. Oneida Indian Nation of New York State, 470 U.S. 226 (1985), was a landmark United States Supreme Court case concerning aboriginal title in the United States. The case, sometimes referred to as Oneida II, was "the first Indian land claim case won on the basis of the Nonintercourse Act."

South Carolina v. Catawba Indian Tribe, Inc., 476 U.S. 498 (1986), is an important U.S. Supreme Court precedent for aboriginal title in the United States decided in the wake of County of Oneida v. Oneida Indian Nation of New York State (1985). Distinguishing Oneida II, the Court held that federal policy did not preclude the application of a state statute of limitations to the land claim of a tribe that had been terminated, such as the Catawba tribe.

United States v. Alfonso D. Lopez, Jr., 514 U.S. 549 (1995), was the first United States Supreme Court case since the New Deal to set limits to Congress' power under the Commerce Clause of the United States Constitution. The Supreme Court held that the federal Gun-Free School Zones Act of 1990, which banned possession of handguns near schools, was unconstitutional because it did not have a substantial impact on interstate commerce. After the Lopez decision, the act was amended to specifically only apply to guns that had been moved via interstate commerce.

<i>Peruta v. San Diego County</i>

Peruta v. San Diego, 824 F.3d 919, was a decision of the United States Court of Appeals for the Ninth Circuit pertaining to the legality of San Diego County's restrictive policy regarding requiring documentation of "good cause" that "distinguish[es] the applicant from the mainstream and places the applicant in harm's way" before issuing a concealed carry permit.

Whitfield v. United States, 574 U.S. ___ (2015), was a United States Supreme Court that concerned whether the forced accompaniment statute under 18 U.S.C. § 2113(e) applies when a bank, credit union, or savings/loan association robber, or attempted robber, forces someone to accompany them for any distance. Defense attorney Joshua B. Carpenter argued on behalf of the Petitioner, and Assistant to the Solicitor General Brian H. Fletcher argued on behalf of the Department of Justice.

Boyle v. United States, 556 U.S. 938 (2009), is a decision by the United States Supreme Court involving what constitutes an "enterprise" under the Racketeer Influenced and Corrupt Organizations Act (RICO). The Court, in a 7-2 opinion, held that any group convened to carry out a crime meets the definition of an enterprise, even if it was only created for that purpose.

Abramski v. United States, 573 U.S. ___ (2014), was a United States Supreme Court case in which the Court found that making arrangements for a straw purchase of a gun is in violation of the Gun Control Act of 1968, and is different from re-selling or gifting a previously purchased gun. In the Abramski case, a former police officer from Virginia took advantage of a local discount to buy a gun for his uncle and later transferred it to Pennsylvania—the uncle's residence—using the appropriate federal procedure. During the purchase, Abramski falsely declared that he is purchasing the gun for himself.

Menominee Tribe of Wis. v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified when litigants are entitled to equitable tolling of a statute of limitations. In a unanimous opinion written by Justice Samuel Alito, the Court held that the plaintiff in this case was not entitled to equitable tolling of the statute of limitations because they did not demonstrate that "extraordinary circumstances" prevented the timely filing of the lawsuit.

Cone v. Bell, 556 U.S. 449 (2009), was a case in which the United States Supreme Court held that a defendant was entitled to a hearing to determine whether prosecutors in his 1982 death penalty trial violated his right to due process by withholding exculpatory evidence. The defendant, Gary Cone, filed a petition for postconviction relief from a 1982 death sentence in which he argued that prosecutors violated his rights to due process under the Fourteenth Amendment by withholding police reports and witness statements that potentially could have shown that his drug addiction affected his behavior. In an opinion written by Justice John Paul Stevens, the Supreme Court held that Cone was entitled to a hearing to determine whether the prosecution's failure to disclose exculpatory evidence violated Cone's right to due process; the Court noted that "the quantity and the quality of the suppressed evidence lends support to Cone’s position at trial that he habitually used excessive amounts of drugs, that his addiction affected his behavior during his crime spree". In 2016, Gary Cone died from natural causes while still sitting on Tennessee's death row.

References

  1. ↑ McLaughlin v. United States, 476 U.S. 16, 17 (1986).
  2. ↑ Bill Barnhart, Justice Stevens & the News Media: An Exercise in Exposition, 106 Nw. U.L. Rev. 657, 694 (2012).
  3. ↑ 18 U.S.C. § 2113(d).
  4. ↑ United States v. Terry, 760 F.2d 939, 942 (9th Cir. 1985).
  5. ↑ United States v. Wardy, 777 F.2d 101, 105-06 (2d Cir. 1985).
  6. ↑ McLaughlin, 476 U.S. at 18 ("We granted certiorari, 474 U.S. 944, 106 S.Ct. 308, 88 L.Ed.2d 285 (1985), to resolve an apparent conflict.").
  7. 1 2 3 4 5 McLaughlin, 476 U.S. at 16.
  8. 1 2 3 4 McLaughlin, 476 U.S. at 17.
  9. ↑ McLaughlin, 476 U.S. at 17 (citing 18 U.S.C. § 2113(d)).
  10. ↑ McLaughlin, 476 U.S. at 17; McLaughlin v. United States, 474 U.S. 944 (1985) (granting certiorari).
  11. ↑ McLaughlin, 476 U.S. at 17-18.
  12. ↑ McLaughlin, 476 U.S. at 18.
<i>United States Reports</i> official record of the rulings, orders, case tables, and other proceedings of the Supreme Court of the United States

The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.