Erlinger v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Erlinger 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 Erlinger v. United States.
In Erlinger v. United States, the Supreme Court addressed whether a jury must determine if past offenses were committed on separate occasions for the Armed Career Criminal Act (ACCA) enhancement. The Court ruled that the Fifth and Sixth Amendments require a unanimous jury to make this determination beyond a reasonable doubt. The decision vacated and remanded the lower court's judgment.
Holding
The single most important “bottom line” of what the Court decided in Erlinger v. United States.
The Court held that the Fifth and Sixth Amendments require a unanimous jury to determine beyond a reasonable doubt whether past offenses were committed on separate occasions for ACCA purposes.
Constitutional Concepts
These are the Constitution-related themes that appear in Erlinger v. United States. Click a concept to see other cases that involve the same idea.
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Why Right to Jury Trial is relevant to Erlinger v. United States
The Court held that a jury must determine whether past offenses were committed on separate occasions for ACCA purposes.
Syllabus excerpt (verbatim)Held: The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant's past offenses were committed on separate occasions for ACCA purposes.
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Why Procedural Due Process is relevant to Erlinger v. United States
The decision emphasizes the requirement of due process in ensuring that factual determinations affecting sentencing are made by a jury.
Syllabus excerpt (verbatim)The Fifth Amendment further promises that the government may not deprive individuals of their liberty without 'due process of law.'
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Why Double Jeopardy is relevant to Erlinger v. United States
The syllabus discusses the Double Jeopardy Clause in relation to the jury's role in determining facts necessary for sentencing.
Syllabus excerpt (verbatim)Amicus next turns to the Double Jeopardy Clause, which permits a judge to look into a defendant's past conduct to ask whether the government has charged a defendant for the same crime a second time.
Key Quotes
Short excerpts from the syllabus in Erlinger v. United States that support the summary and concepts above.
The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt.
The government confessed error.
This Court decides no more than that.
