Logan v. United States, 552 U.S. 23 (2007)
Primary Holding
The "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.
In the case of Logan v. United States, the Supreme Court ruled that if someone has a past conviction but never lost their civil rights (like the right to vote), they can't use that to avoid harsher penalties for future crimes, such as being a felon with a gun. This matters because it clarifies that certain legal protections for offenders don't apply if they were never deprived of their rights in the first place. This case is relevant for anyone with a criminal record who might think they can get a lighter sentence based on their civil rights status; it shows that the law is strict about who qualifies for those protections.
AI-generated plain-language summary to help you understand this case
In the case of Logan v. United States, 552 U.S. 23 (2007), petitioner James D. Logan was convicted in a United States District Court for being a felon in possession of a firearm, which violated 18 U.S.C. §922(g)(1). Logan's criminal history included three relevant state convictions, which qualified him as a recidivist under the Armed Career Criminal Act (ACCA) of 1984. Consequently, the District Court imposed a 15-year prison sentence, the minimum required under the ACCA. Notably, none of Logan's prior convictions had been expunged, set aside, or pardoned, and the convictions did not result in the loss of his civil rights. Logan challenged his enhanced sentence on the grounds that the "civil rights restored" exemption in 18 U.S.C. §921(a)(20) should apply to his case, arguing that it should encompass state-court convictions that did not deprive him of civil rights. This issue was brought before the United States Court of Appeals for the Seventh Circuit, which upheld the District Court's decision. Logan subsequently sought a writ of certiorari from the Supreme Court, which agreed to hear the case. The relevant background context includes the provisions of the ACCA, which imposes harsher penalties on individuals with multiple felony convictions, and the specific language of §921(a)(20), which outlines the conditions under which prior convictions may be disregarded for sentencing purposes. The Supreme Court's decision focused on the interpretation of whether the exemption for restored civil rights applies to individuals like Logan, who had never lost their civil rights due to their convictions.
Whether the “civil rights restored” exemption in 18 U.S.C. §921(a)(20) applies to state-court convictions that did not result in the loss of civil rights, thereby excluding them from the Armed Career Criminal Act's sentencing enhancements.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 30, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
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.
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.
Greenlaw v. United States, 554 U.S. 237 (2008)
Consumer WonA United States Court of Appeals cannot, on its own initiative, increase a defendant's sentence absent a Government appeal or cross-appeal.