Burgess v. United States, 553 U.S. 124 (2008)
Primary Holding
The 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.
In the case of Burgess v. United States, the Supreme Court decided that a state drug offense can be considered a "felony drug offense" even if the state classifies it as a misdemeanor, as long as it carries a punishment of more than one year in prison. This matters because it means that people with certain past drug convictions could face much longer sentences for new federal drug charges, which affects their legal consequences. For consumers, this case highlights the importance of understanding how past convictions can impact future legal situations, especially in drug-related cases.
AI-generated plain-language summary to help you understand this case
In the case of Burgess v. United States, 553 U.S. 124 (2008), the underlying dispute arose from Keith Lavon Burgess's guilty plea to conspiracy to possess with intent to distribute 50 grams or more of cocaine base, which is a violation of federal law under 21 U.S.C. §§841(a) and 846. The federal law imposes a mandatory minimum sentence of 10 years for such an offense, but this minimum increases to 20 years if the defendant has a prior conviction for a "felony drug offense." Burgess had a previous conviction for possession of cocaine under South Carolina law, which was classified as a misdemeanor but punishable by up to two years in prison. The government argued that this prior conviction qualified as a "felony drug offense" under federal law, thus mandating the 20-year minimum sentence. The procedural history of the case began in the United States District Court for the District of South Carolina, where the court ruled that Burgess's prior state conviction met the criteria for a "felony drug offense" as defined by 21 U.S.C. §802(44), which states that such an offense is one punishable by imprisonment for more than one year, regardless of its classification under state law. Burgess contested this interpretation, arguing that the term "felony drug offense" should incorporate the definition of "felony" from §802(13), which requires an offense to be classified as a felony under state law to qualify. The District Court ultimately sided with the government, leading to a 20-year minimum sentence for Burgess. The relevant background context involves the interpretation of federal drug sentencing laws, specifically the Controlled Substances Act, which establishes mandatory minimum sentences for drug offenses. The case hinged on the definitions provided in the Act, particularly the distinction between offenses classified as felonies and those that are not. This interpretation was critical in determining whether Burgess's prior misdemeanor conviction could enhance his federal sentence, thereby raising questions about the interplay between state classifications of offenses and federal sentencing guidelines.
Whether a state drug offense classified as a misdemeanor, but punishable by more than one year’s imprisonment, qualifies as a “felony drug offense” under 21 U.S.C. §841(b)(1)(A).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- March 24, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- 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.
Lopez v. Gonzales, 549 U.S. 47 (2006)
Consumer WonA state offense that is classified as a felony under state law but is a misdemeanor under the Controlled Substances Act does not qualify as a "felony punishable under the Controlled Substances Act" for the purposes of determining whether it constitutes an aggravated felony under immigration law.
United States v. Booker, 543 U.S. 220 (2005)
Consumer LostThe Federal Sentencing Guidelines are unconstitutional as applied in a manner that requires judges to find facts by a preponderance of the evidence that increase a defendant's sentence beyond the statutory maximum, violating the Sixth Amendment right to a jury trial.
Salinas v. United States, 547 U.S. 188 (2006)
Consumer WonA prior conviction for simple possession of a controlled substance does not qualify as a "controlled substance offense" under the United States Sentencing Guidelines, as it does not involve intent to manufacture, import, export, distribute, or dispense.