Beckles v. U.S.

The Federal Sentencing Guidelines are not subject to vagueness challenges under the Due Process Clause because they only guide the exercise of a court's discretion.

Petitioner was convicted for “possession of a firearm by a convicted felon.” During sentencing, the district court consulted the Federal Sentencing Guidelines under §4B1.2 (“Guidelines”), and Petitioner was sentenced to 360 months to life. The Guidelines’ commentary specified that Petitioner’s possession of a sawed-off shotgun constituted a “crime of violence” pursuant to §4B1.2(a)’s residual clause that included crimes “otherwise involv[ing] conduct that presents a serious potential risk of physical injury to another.” The “crime of violence” made Petitioner eligible for “career criminal” status, which, in turn, placed Petitioner in an enhanced sentencing range under the Guidelines. The Eleventh Circuit Court of Appeals affirmed the conviction and sentence. On appeal, the United States Supreme Court vacated and remanded to the Eleventh Circuit for reconsideration in light of its decision in Johnson v. United States (2015), and the Eleventh Circuit again affirmed. On second appeal to the United States Supreme Court, the question presented was whether the residual clause was void for vagueness in violation of Petitioner’s due process rights. In Johnson, an identical residual clause under the Armed Career Criminal Act (“ACCA”) was declared unconstitutional. The Court distinguished Johnson, because the Guidelines were reduced to an advisory tool by the Court’s decision in United States v. Booker (2005), holding that trial courts may disregard the Guidelines and defer to their own individualized assessment for each sentence. Based on the advisory nature of the Guidelines, the Court determined that the constitutional concerns under void for vagueness doctrine were not implicated, and no due process was violated. AFFIRMED.