Brown v. United States
Issues
When sentencing a defendant for a federal firearm offense, how should courts determine whether the defendant’s past state drug conviction is a “serious drug offense” warranting a higher minimum sentencing requirement?
This case asks the Supreme Court to determine when the Armed Career Criminal Act (18 U.S.C. § 924(e)) (“ACCA”) applies to a defendant with prior state drug offenses who is facing sentencing for a Gun Control Act (18 U.S.C. § 922(g)) (“GCA”) violation. The ACCA is a “three–strikes” law which imposes a 15–year mandatory minimum imprisonment term on defendants convicted of violating the GCA and at least three prior violent felonies or “serious drug offenses.” However, a prior state drug offense only counts as a “strike” under the ACCA if the relevant state drug prohibition categorically matches its federal counterpart. Brown argues that federal and state laws must match at the time of sentencing for the GCA violation. Brown claims that his interpretation most closely aligns with the ACCA’s plain meaning and serves judicial efficiency because compliance is easier. The United States argues that federal and state laws must match at the time of the prior state drug offense. The United States claims that its interpretation most aligns with the ACCA’s legislative intent and promotes consistency in the criminal justice system. This case touches on important questions regarding fair notice to criminal defendants as well as federal controlled–substances schedules’ responsiveness to scientific and social developments.
Questions as Framed for the Court by the Parties
Whether the "serious drug offense" definition in the Armed Career Criminal Act incorporates the federal drug schedules that were in effect at the time of the federal firearm offense or the federal drug schedules that were in effect at the time of the prior state drug offense.
The Armed Career Criminal Act (“ACCA”) imposes a fifteen–year mandatory minimum imprisonment term when a defendant violates the Gun Control Act, codified under 18 U.S.C.
Additional Resources
- Kimberly Strawbridge Robinson, Supreme Court to Consider Sentencing in Light of New Drug Laws, Bloomberg Law (May 15, 2023).
- Katherine Fung, Supreme Court Faces High–Stakes Cases: What to Know, Newsweek (Oct. 2, 2023).