mandatory sentencing

Issues

The Armed Career Criminal Act of 1984 (ACCA), applies to felons convicted of firearms possession who have previously been convicted of three or more serious crimes, including state drug offenses with a maximum sentence of ten or more years. A federal district court sentenced Gino Rodriquez to 92 months' imprisonment after a jury found him guilty of possessing a firearm as a felon. The Government appealed, arguing the court should have applied the ACCA, which requires a minimum fifteen-year sentence. The ACCA does not tell federal judges how to determine what the maximum possible sentence for an underlying crime was under state law. The Government argues that when a crime is committed by a repeat offender, or "recidivist," at the time of their prior conviction, the court should include in the maximum any sentence enhancements imposed based on the offender's recidivism. Rodriquez argues the maximum sentence should be only the statutory maximum for the crime charged, excluding such enhancements. The sentence in question here is a 1995 drug conviction Rodriquez received under Washington State law. The Government said the conviction qualified as an ACCA predicate because in 1995 Rodriquez was a repeat offender and Washington law provided a ten-year peak sentence for such offenders. The district court ruled that Ninth Circuit and Supreme Court precedents required it to consider only the sentence for the underlying crime without additional penalties for recidivism. The Ninth Circuit affirmed. In this case, the United States Supreme Court will clarify how federal courts should treat recidivist sentence enhancements when determining the maximum sentence for a state drug conviction for ACCA purposes. This decision will add to the Court's rapidly developing interpretation of the ACCA.

Questions as Framed for the Court by the Parties

Additional Resources

Issues

Following a transaction in which he exchanged illegally-obtained prescription drugs for a firearm, Petitioner Watson was prosecuted under 18 U.S.C. § 924(c)(1)(A) for "use" of a firearm during and in relation to a drug trafficking crime. In addition to sentences imposed under other federal statutes, Watson received a mandatory consecutive five year sentence, imposed under 18 U.S.C. § 924(c)(1)(D). Watson pled guilty but reserved the right to challenge whether the agreed-upon facts supported his conviction. The Fifth Circuit confirmed his conviction, finding that receiving a firearm constitutes "use" under the statute and under Supreme Court law set forth in Bailey v. United States, which defined "use" as "active employment" of the firearm. Watson argues that receiving a firearm is insufficient to constitute use, while the United States contends that both receiving and offering a firearm constitute "active employment" and therefore "use" under the statute. The Court's decision will set uniform standards of punishment throughout the country. A finding for Watson could reduce crowding in an already overburdened prison system, while a decision for the United States could reduce the strain on a similarly overburdened court system.

Questions as Framed for the Court by the Parties

Additional Resources