Descamps v. United States

Descamps v. United States, 570 U.S. 254 (2013), was a case in which the United States Supreme Court clarified standards for evaluating potential prior offenses under the Armed Career Criminal Act (ACCA).[1] In an 8–1 decision written by Justice Elena Kagan, the Supreme Court held that judges may only look at the statutory elements of a crime, rather than the facts associated with that particular crime, "when the crime of which the defendant was convicted has a single, indivisible set of elements."[2] In his review of the case for SCOTUSblog, Daniel Richman opined that following the Court's decision, "[w]hether or not a prior conviction is going to 'count' will have to be determined as mechanically as possible."[3]

Descamps v. United States
Argued January 7, 2013
Decided June 20, 2013
Full case nameMatthew Robert Descamps, Petitioner v. United States Attorney- Dan B. Johnson, Spokane, Washington.
Docket no.11-9540
Citations570 U.S. 254 (more)
133 S. Ct. 2276; 186 L. Ed. 2d 438; 2013 U.S. LEXIS 4698, 81 U.S.L.W. 4490
Opinion announcementOpinion announcement
Holding
Under the Armed Career Criminal Act, judges may not look at facts associated with a crime (the "modified categorical approach") when criminal statutes contain a single, indivisible set of elements
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityKagan, joined by Roberts, Scalia, Kennedy, Ginsburg, Breyer, Sotomayor
ConcurrenceKennedy
ConcurrenceThomas (in judgment)
DissentAlito
Laws applied
Armed Career Criminal Act

See also

References

  1. Descamps v. United States, 570 U.S. 254 (2013).
  2. Descamps, slip op. at 2.
  3. Daniel Richman, Opinion analysis: When is a burglary not a burglary?, SCOTUSblog (Jun. 20, 2013).


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