Borden v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Borden 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 Borden v. United States.
The Supreme Court reversed the Sixth Circuit's decision, ruling that a criminal offense with a mens rea of recklessness does not qualify as a 'violent felony' under the Armed Career Criminal Act (ACCA). The Court emphasized that the statutory text requires the use of force 'against the person of another,' which implies a higher degree of intent than recklessness. Justice Kagan delivered the opinion, joined by Justices Breyer, Sotomayor, and Gorsuch, while Justice Thomas concurred in the judgment.
Holding
The single most important “bottom line” of what the Court decided in Borden v. United States.
The Court held that a criminal offense with a mens rea of recklessness does not qualify as a 'violent felony' under ACCA's elements clause.
Constitutional Concepts
These are the Constitution-related themes that appear in Borden 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 Borden v. United States
The case involves interpreting the statutory language of ACCA's elements clause to determine if it is too vague in including reckless offenses as violent felonies.
Syllabus excerpt (verbatim)Classifying reckless crimes as 'violent felonies' would also conflict with ACCA's purpose.
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Why Substantive Due Process is relevant to Borden v. United States
The decision involves determining the level of mens rea required for a crime to be considered a violent felony under ACCA, implicating substantive due process concerns.
Syllabus excerpt (verbatim)Reckless conduct is not aimed in that prescribed manner.
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Why Cruel and Unusual Punishment is relevant to Borden v. United States
The case discusses the appropriateness of enhanced sentencing under ACCA, which could relate to the proportionality of punishment.
Syllabus excerpt (verbatim)An offender who has repeatedly committed 'purposeful, violent, and aggressive' crimes poses an uncommon danger.
Key Quotes
Short excerpts from the syllabus in Borden v. United States that support the summary and concepts above.
Reckless conduct is not aimed in that prescribed manner.
The phrase 'against another,' when modifying a volitional action like the 'use of force,' demands that the perpetrator direct his force at another individual.
An offender who has repeatedly committed 'purposeful, violent, and aggressive' crimes poses an uncommon danger of 'us[ing a] gun deliberately to harm a victim.'
