Lockhart v. United States

When interpreting a statute, a court should interpret a limiting clause or phrase at the end of the sentence to only modify the noun or phrase immediately preceding it.

Petitioner pleaded guilty to possession of child pornography in violation of 18 U.S.C. §2252(a)(4). Because of Petitioner’s prior state conviction for sexual abuse of his adult girlfriend in 2000, the District Court applied an increased maximum sentence of 10 to 20 years per 18 U.S.C. §2252(b)(2) and the Second Circuit affirmed. Under §2252(b)(2), a prior state conviction “relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward” requires an enhanced maximum sentence. Petitioner argued that the modifying language “involving a minor or a ward” should apply to all three statutory provisions, thus eliminating his prior conviction from the sentencing decision. The Supreme Court held that the increased maximum sentence should stand because the Court has typically applied “the rule of the last antecedent,” which interprets a modifying clause to only apply to the phrase it immediately follows. The Court reasoned that §2252(b)(2) does not contain language that would lead readers to apply the modification naturally to all three provisions. Additionally, the Court found that the distinction of the last provision parallels the Federal Criminal Code §109A, as the headings include the modification for the third provision only. Finally, the Court found that the rule of lenity should not apply for simple grammatical principles and that stretching the modification across all three provisions would make them nearly synonymous. Affirmed.