James v. United States, 550 U.S. 192 (2007)
Primary Holding
Attempted 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.
In the case of James v. United States, the Supreme Court decided that attempted burglary counts as a "violent felony" under federal law. This is important because it means that if someone has three felony convictions, including attempted burglary, they face a mandatory minimum sentence of 15 years in prison for possessing a firearm, even if their current crime isn't violent. This ruling helps protect consumers by reinforcing strict penalties for repeat offenders, which can contribute to safer communities by keeping dangerous individuals off the streets. If someone has prior felony convictions and is facing charges related to firearms, this case is relevant as it could significantly impact their sentencing.
AI-generated plain-language summary to help you understand this case
In the case of **James v. United States**, Alphonso James, Jr. was convicted in federal court for possessing a firearm as a convicted felon, violating 18 U.S.C. §922(g)(1). James had three prior felony convictions, one of which was for attempted burglary in Florida. This conviction was significant because the Armed Career Criminal Act (ACCA) mandates a minimum sentence of 15 years for individuals with three prior convictions for violent felonies or serious drug offenses. At sentencing, the government argued that James qualified for this mandatory minimum due to his prior convictions, including the attempted burglary. The procedural history of the case began with James's guilty plea, where he acknowledged his prior felony convictions. During sentencing, he contested the classification of his attempted burglary conviction as a "violent felony" under the ACCA. The District Court ruled that attempted burglary did qualify as a violent felony, and this decision was upheld by the Eleventh Circuit Court of Appeals. Subsequently, the Supreme Court granted certiorari to address the specific question of whether attempted burglary, as defined by Florida law, constitutes a violent felony under the ACCA. The background context of this case revolves around the definitions and implications of the ACCA, which aims to impose stricter penalties on repeat offenders. The law defines a "violent felony" in two clauses, one of which pertains to crimes involving physical force, while the other includes specific offenses like burglary. The Florida statutes at the time defined burglary in a manner that allowed for the conviction of attempted burglary, which was punishable by imprisonment for more than one year. The Supreme Court's decision ultimately affirmed the lower court's ruling that attempted burglary qualifies as a violent felony under the ACCA.
Whether attempted burglary, as defined by Florida law, qualifies as a "violent felony" under the Armed Career Criminal Act (ACCA).
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 7, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Alito
- Damages Awarded
- N/A
- Data Quality
- high
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.
Logan v. United States, 552 U.S. 23 (2007)
Consumer LostThe "civil rights restored" exemption in 18 U.S.C. §921(a)(20) does not apply to state-court convictions that did not result in a loss of civil rights, meaning that offenders who retained their civil rights at all times are not eligible for relief from the consequences of their convictions under this provision.
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.
Begay v. United States, 553 U.S. 137 (2008)
Consumer WonDriving 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.