Kansas v. Garcia
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Kansas v. Garcia and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Kansas v. Garcia.
In Shular v. United States, the Supreme Court addressed whether the Armed Career Criminal Act (ACCA) requires a comparison of state drug offenses to generic offenses for sentence enhancement. The Court concluded that the ACCA's definition of 'serious drug offense' pertains to conduct specified in the statute, not to generic offenses. The decision affirmed that Shular's prior convictions under Florida law qualified for ACCA enhancement.
Holding
The single most important “bottom line” of what the Court decided in Kansas v. Garcia.
The Court held that Section 924(e)(2)(A)(ii)'s 'serious drug offense' definition requires only that the state offense involve the conduct specified in the statute.
Constitutional Concepts
These are the Constitution-related themes that appear in Kansas v. Garcia. Click a concept to see other cases that involve the same idea.
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Why Ex Post Facto is relevant to Kansas v. Garcia
The case involves the interpretation of statutory language to determine if past convictions qualify for enhanced sentencing, which relates to how laws apply to past actions.
Syllabus excerpt (verbatim)Rejecting a generic-offense approach, Shular contends, would subject defendants to ACCA enhancement based on outlier state laws.
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Why Void for Vagueness is relevant to Kansas v. Garcia
The case discusses the clarity of statutory language in defining 'serious drug offenses' for the purpose of sentencing enhancement.
Syllabus excerpt (verbatim)The rule of lenity has no application here, for after consulting traditional canons of interpretation there remains no ambiguity for the rule of lenity to resolve.
Key Quotes
Short excerpts from the syllabus in Kansas v. Garcia that support the summary and concepts above.
Section 924(e)(2)(A)(ii)'s 'serious drug offense' definition requires only that the state offense involve the conduct specified in the statute.
The statutory text and context show that § 924(e)(2)(A)(ii) refers to conduct, not offenses.
Congress intended consistent application of ACCA to all offenders who engaged—according to the elements of their prior convictions—in certain conduct.
