Supreme Court limits use of prior convictions to enhance sentencing

[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] 8-1 Thursday in Descamps v. United States [SCOTUSblog backgrounder] to limit the way sentencing courts can use prior convictions to enhance sentencing for federal crimes. The question before the court was whether Matthew Descamps' burglary conviction under California law could allow a conviction under federal burglary law, which had slightly different requirements than California's statute. Federal judges used the "modified categorical approach" and looked at a limited number of documents to determine that Descamps was convicted of the elements of the generic crime under federal law. Thus, when Descamps was convicted of a federal felony, the government translated his previous California crime to a federal one to increase his sentence under the Armed Career Criminal Act [text] (ACCA). In an opinion by Justice Elena Kagan, the court held, "that sentencing courts may not apply the modified categorical approach when the crime of which the defendant was convicted has a single, indivisible set of elements."

the District Court should not have enhanced his sentence under ACCA. That court and the Ninth Circuit erred in invoking the modified categorical approach to look behind Descamps' conviction in search of record evidence that he actually committed the generic offense. The modified approach does not authorize a sentencing court to substitute such a facts-based inquiry for an elements-based one. A court may use the modified approach only to determine which alternative element in a divisible statute formed the basis of the defendant’s conviction.
The court reversed the decision of the US Court of appeals for the Ninth Circuit.

Justices Antohny Kennedy and Clarence Thomas filed concurring opinions. Justice Samuel Alito filed a dissent. Alito wrote that he "would give ACCA a more practical reading. When it is clear that a defendant necessarily admitted or the jury necessarily found that the defendant committed the elements of generic burglary, the conviction should qualify." At oral arguments [JURIST report] in January, Descamps' attorney argued that his client was deprived of having the federal crime proven beyond a reasonable doubt, and that the elements of California burglary are too removed from the federal elements. The United States government argued that, since Descamps pleaded guilty, he pleaded guilty to the generic crime of burglary, not the elements.

 

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