Johnson V. United States Armed Career Criminal Act Case
Background: Armed Career Criminal Act (ACCA)
Passed in 1984, the ACCA enhances penalties for felons with 3+ prior convictions for serious violent crimes or serious drug offenses.
The key issue often is what qualifies as a "violent felony."
The law uses a "residual clause" that was often challenged for vagueness.
1. Johnson v. United States (2015) — The Big Landmark
Facts: Johnson was convicted under ACCA, enhanced because a prior offense fell under ACCA's “residual clause” defining violent felonies.
Issue: Is the residual clause in ACCA unconstitutionally vague?
Holding: Supreme Court struck down the residual clause as unconstitutionally vague under the Due Process Clause.
Significance: The ruling invalidated many prior ACCA sentence enhancements based on vague definitions, leading to sentence reductions and retrials.
2. Welch v. United States (2016)
Facts: Welch challenged his ACCA sentence based on the Johnson decision.
Issue: Whether Johnson applies retroactively to cases on collateral review.
Holding: Supreme Court held Johnson applies retroactively, allowing many prisoners to challenge their sentences.
Significance: Allowed many ACCA-enhanced prisoners to seek relief.
3. Descamps v. United States (2013)
Facts: Questioned whether the “categorical approach” or the specific facts of a prior conviction determine ACCA applicability.
Issue: How to assess prior convictions when applying ACCA.
Holding: Supreme Court ruled courts must use the categorical approach—look at the statutory elements, not underlying facts.
Significance: Narrowed ACCA's application; courts can't use case-specific facts to qualify prior convictions.
4. Sessions v. Dimaya (2018)
Facts: Similar vagueness challenge to a different federal statute (Immigration and Nationality Act) with language like ACCA’s residual clause.
Issue: Is the "residual clause" in immigration law vague?
Holding: Supreme Court found the clause unconstitutionally vague.
Significance: Extended Johnson’s reasoning to other statutes with similar language.
5. Mathis v. United States (2016)
Facts: Dispute over how to interpret state burglary statutes for ACCA purposes.
Issue: Whether state conviction counts as violent felony under ACCA.
Holding: Courts must compare the statute's elements, not the facts of the case; ambiguous statutes are interpreted narrowly.
Significance: Strengthened the categorical approach in ACCA cases.
6. Borden v. United States (2021)
Facts: Questioned whether “reckless” conduct qualifies as a violent felony under ACCA.
Issue: Does reckless conduct qualify as “violent felony”?
Holding: Supreme Court ruled reckless conduct does not count as violent felony under ACCA.
Significance: Further limits ACCA’s reach; focuses on intentional or knowing conduct.
Summary Table
| Case | Year | Issue | Holding | Significance |
|---|---|---|---|---|
| Johnson v. US | 2015 | ACCA residual clause vagueness | Clause struck down as unconstitutionally vague | Limited ACCA enhancements; huge impact |
| Welch v. US | 2016 | Retroactivity of Johnson | Johnson applies retroactively | Allowed many sentence challenges |
| Descamps v. US | 2013 | Categorical approach to prior convictions | Use statute elements, not facts | Narrowed ACCA application |
| Sessions v. Dimaya | 2018 | Vagueness in similar immigration law | Residual clause vague | Extended vagueness principle to other laws |
| Mathis v. US | 2016 | Interpretation of state burglary statutes | Categorical approach required | Protected defendants from broad application |
| Borden v. US | 2021 | Recklessness as violent felony? | Reckless conduct not violent felony | Focus on intentional conduct only |
Why are these cases important?
They limit the scope of ACCA sentence enhancements, protecting defendants from vague or overly broad definitions.
Emphasize using the categorical approach—looking at the legal definitions of crimes, not individual facts.
Help define what kinds of prior convictions can trigger long mandatory sentences.
Ensure due process by preventing vague laws from increasing sentences arbitrarily.
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