On January 13, 2009, the US Supreme Court ruled in Chambers v. United States that failure to report to prison did not constitute a "violent felony" for purposes of sentence enhancement under the Armed Career Criminals Act (ACCA) [18 USC § 924(e)]. Petitioner Deondery Chambers pleaded guilty to being a felon in possession of a firearm. At sentencing, the state of Illinois argued that he was subject to a 15-year mandatory minimum sentence under the ACCA, based in part on a prior conviction for escape when he failed to report to prison. The ruling reversed the decision of the US Court of Appeals for the Seventh Circuit and resolved a circuit split on the issue with the Ninth and DC Circuits having held that failure to report is not a violent felony and the other 10 circuits having held that it is.
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