Begay v. United States, 553 U.S. 137 (2008)
Primary Holding
Driving under the influence of alcohol (DUI) does not qualify as a "violent felony" under the Armed Career Criminal Act, as it does not involve conduct that presents a serious potential risk of physical injury to another.
In the case of Begay v. United States, the Supreme Court decided that driving under the influence (DUI) does not count as a "violent felony" under a specific federal law that increases prison sentences for certain repeat offenders. This matters because it means that people convicted of DUI won't face the same harsh penalties as those convicted of more dangerous crimes, which can help prevent overly severe punishments for non-violent offenses. This case is relevant for anyone facing charges related to DUI, as it clarifies that such offenses won't lead to the same consequences as violent crimes when it comes to sentencing.
AI-generated plain-language summary to help you understand this case
In September 2004, Larry Begay was arrested by New Mexico police after allegedly threatening his sister and aunt with a rifle. Following his arrest, Begay, who acknowledged his status as a felon, pleaded guilty to unlawful possession of a firearm, violating federal law under 18 U.S.C. §922(g)(1). A presentence report revealed that Begay had a history of multiple DUI convictions, which, under New Mexico law, become classified as felonies after the fourth offense. As a result, the sentencing judge determined that Begay had at least three prior felony DUI convictions, leading to the conclusion that he qualified for a mandatory minimum sentence of 15 years under the Armed Career Criminal Act (ACCA) for having three prior convictions for a "violent felony." Begay contested the classification of his DUI convictions as "violent felonies," arguing that they did not meet the criteria set forth in the ACCA. The case progressed through the judicial system, with the Tenth Circuit Court of Appeals ultimately ruling against him by a 2-1 vote, affirming the lower court's decision that his DUI convictions did indeed involve conduct presenting a serious potential risk of physical injury to others. Following this ruling, Begay sought certiorari from the Supreme Court, which agreed to hear the case to determine whether driving under the influence of alcohol qualifies as a "violent felony" under the terms of the ACCA. The background context of the case centers on the interpretation of the ACCA, which imposes stricter sentencing guidelines for felons who possess firearms and have prior convictions for certain crimes. The specific legal question at hand was whether the nature of DUI offenses, particularly in the context of New Mexico's laws, could be classified as violent felonies given the potential risks associated with such conduct. The Supreme Court's decision would clarify the scope of the ACCA and its application to DUI offenses.
Whether driving under the influence of alcohol constitutes a "violent felony" under the Armed Career Criminal Act's definition.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 15, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
United States v. Rodriquez, 553 U.S. 377 (2008)
Consumer LostA state drug-trafficking conviction qualifies as a "serious drug offense" under the Armed Career Criminal Act if the maximum term of imprisonment prescribed by law for the offense is ten years or more, including recidivist enhancements.
James v. United States, 550 U.S. 192 (2007)
Consumer LostAttempted burglary, as defined by Florida law, qualifies as a "violent felony" under the Armed Career Criminal Act (ACCA), thereby subjecting a defendant with three prior convictions to a mandatory minimum sentence of 15 years for possession of a firearm by a convicted felon.
Shepard v. United States, 544 U.S. 13 (2005)
Consumer LostA sentencing court under the Armed Career Criminal Act (ACCA) may not consider police reports or complaint applications to determine whether a prior guilty plea necessarily admitted to generic burglary; it is generally limited to examining the statutory definition, charging document, written plea agreement, transcript of plea colloquy, and any explicit factual finding by the trial judge to which the defendant assented.
Burgess v. United States, 553 U.S. 124 (2008)
Consumer LostThe term “felony drug offense” in 21 U.S.C. §841(b)(1)(A) is defined exclusively by 21 U.S.C. §802(44) and includes state drug offenses that are punishable by imprisonment for more than one year, regardless of whether the state law classifies the offense as a misdemeanor.