- Court: United States Supreme Court
- Area(s) of Law: Criminal Law
- Date Filed: June 10, 2021
- Case #: 19–5410
- Judge(s)/Court Below: Kagan, J., announced the judgment of the Court and delivered an opinion in which Breyer, Sotomayer, and Gorsuch, JJ., joined. Thomas, J., filed an opinion concurring in the judgment. Kavanaugh, J., filed a dissenting opinion, in which Roberts, C. J., Alito, and Barrett, JJ., joined.
- Full Text Opinion
The Armed Career Criminal Act (ACCA) mandates a 15-year minimum sentence for a person who has three or more violent felony convictions and who is later found in possession of a gun. A “violent felony” includes “the use, attempted use, or threatened use of physical force against the person of another.” Petitioner pleaded guilty to a felon-in-possession charge and the Government pursued enhanced sentencing under the ACCA. Petitioner argued reckless conduct did not qualify as a violent felony under the ACCA because the word “against,” within the statute, implied a knowing or purposeful intent. The Government argued that “against” translated into mere contact with another person. The Court held that the ACCA element clause excludes reckless offenses, and reasoned that the decision turned on purpose and context. The court determined that Congress’ purpose with the ACCA was narrow and meant to address the “special danger” posed by “armed career criminals.” Further, the Court reasoned that in context, the word “against” modifies the words “use of physical force,” and the use of physical force is a volitional act. Thus, the Court concluded that the ACCA applies to individuals who have committed three or more acts of violence with a mens rea greater than recklessness. REVERSED AND REMANDED.