Shular v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Shular v. United States 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 Shular v. United States.
In Shular v. United States, the Supreme Court addressed whether the definition of 'serious drug offense' under the Armed Career Criminal Act (ACCA) requires a comparison to generic offenses. The Court affirmed the Eleventh Circuit's decision, concluding that the statute refers to conduct, not offenses, and does not require a generic-offense analysis. The decision clarified that the ACCA enhancement applies based on the conduct specified in the statute.
Holding
The single most important “bottom line” of what the Court decided in Shular v. United States.
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 Shular v. United States. Click a concept to see other cases that involve the same idea.
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Why Void for Vagueness is relevant to Shular v. United States
The Court's interpretation of the ACCA's 'serious drug offense' definition addresses concerns about the clarity and application of statutory language.
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.
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Why Procedural Due Process is relevant to Shular v. United States
The case involves determining the procedural requirements for applying sentence enhancements under ACCA, which implicates fair notice and consistent application.
Syllabus excerpt (verbatim)Congress intended consistent application of ACCA to all offenders who engaged—according to the elements of their prior convictions—in certain conduct.
Key Quotes
Short excerpts from the syllabus in Shular v. United States 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.
