Brown v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Brown 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 Brown v. United States.
The Supreme Court addressed whether state drug convictions qualify as predicates under the Armed Career Criminal Act (ACCA) if the drug was later removed from federal schedules. The Court affirmed that a state drug conviction counts as an ACCA predicate if the drug was on the federal schedules at the time of the offense. This decision impacts the application of enhanced sentencing for firearm possession by convicted felons.
Holding
The single most important “bottom line” of what the Court decided in Brown v. United States.
The Court held that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.
Constitutional Concepts
These are the Constitution-related themes that appear in Brown v. United States. Click a concept to see other cases that involve the same idea.
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Why Ex Post Facto is relevant to Brown v. United States
The case involves whether a state drug conviction counts as an ACCA predicate if the drug was later removed from the federal schedules, which relates to the prohibition on retroactively applying criminal laws to increase punishment.
Syllabus excerpt (verbatim)The question presented is whether a state crime constitutes a 'serious drug offense' if it involved a drug that was on the federal schedules when the defendant possessed or trafficked in it but was later removed.
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Why Procedural Due Process is relevant to Brown v. United States
The case involves the application of sentencing enhancements based on prior convictions, which implicates procedural due process in ensuring fair legal proceedings.
Syllabus excerpt (verbatim)Petitioners' additional arguments do not persuade... Finally, petitioners contend that the rule of lenity counsels in favor of their interpretations.
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Why Void for Vagueness is relevant to Brown v. United States
The arguments about the clarity of the ACCA's application to state drug offenses when federal definitions change suggest concerns about vagueness.
Syllabus excerpt (verbatim)Petitioners' additional arguments do not persuade... But lenity applies only if a statute remains grievously ambiguous.
Key Quotes
Short excerpts from the syllabus in Brown v. United States that support the summary and concepts above.
A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.
Petitioners' interpretations, by contrast, would treat those federal and state offenses differently.
The Government's interpretation also best fulfills ACCA's statutory objectives.
