United States v. Ressam, 553 U.S. 272 (2008)
Primary Holding
The term "during" in 18 U.S.C. §844(h)(2) denotes a temporal link, meaning that a defendant can be convicted of carrying an explosive "during the commission of" a felony without needing to establish a specific relationship between the explosive and the underlying felony.
In the case of United States v. Ressam, a man tried to enter the U.S. with explosives hidden in his car, intending to use them for a terrorist attack. The Supreme Court ruled that he could be convicted of carrying those explosives while committing another crime, even if the explosives weren't directly related to that crime. This ruling helps protect consumers by reinforcing strict penalties for carrying dangerous items during criminal activities, making it clear that such actions will be taken seriously, especially in situations that could threaten public safety. This case is relevant if someone is involved in or witnesses a crime where explosives or dangerous items are present, as it emphasizes the legal consequences of such actions.
AI-generated plain-language summary to help you understand this case
In the case of United States v. Ressam, Ahmed Ressam, an Algerian national, attempted to enter the United States via car ferry at Port Angeles, Washington, on December 14, 1999. He was found to have hidden explosives in the trunk of his rental car, which he intended to detonate at Los Angeles International Airport. Upon arrival, Ressam was questioned by a customs official and falsely identified himself as a Canadian citizen named Benni Noris. After completing a customs declaration form, he was directed to a secondary inspection station where officials discovered the explosives concealed in the spare tire well of his vehicle. Ressam was subsequently convicted of multiple offenses, including making a false statement to a customs official and carrying an explosive during the commission of that felony. The Ninth Circuit Court of Appeals later overturned his conviction for the explosive charge, interpreting the statute to require a relationship between the act of carrying the explosive and the underlying felony. This interpretation conflicted with decisions from other appellate courts, prompting the Supreme Court to grant certiorari to resolve the issue. The case arose under 18 U.S.C. §844(h)(2), which addresses the carrying of explosives during the commission of a felony. The Supreme Court's review focused on the statutory language and the intent of Congress when enacting the law, particularly whether the term "during" necessitated a specific connection between the explosive and the underlying felony. The Court ultimately found that Ressam's actions met the criteria outlined in the statute, as he was carrying the explosives at the same time he was committing the felony of making false statements.
Whether the term "during," as used in 18 U.S.C. §844(h)(2), requires a temporal connection between the carrying of an explosive and the underlying felony, or whether it is sufficient that the carrying of the explosive occurred contemporaneously with the commission of the felony.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- March 25, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- 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.
Regalado Cuellar v. United States, 553 U.S. 550 (2008)
Consumer WonThe federal money laundering statute requires the government to demonstrate that a defendant engaged in conduct beyond merely hiding illicit funds during transport; it must show that the defendant took steps to conceal the illegal nature of the funds in a manner that indicates an intent to promote or conceal unlawful activity.
United States v. Resendiz-Ponce, 549 U.S. 102 (2007)
Consumer LostThe omission of an essential element of a criminal offense from a federal indictment constitutes a fatal flaw, and such an error is not subject to harmless error analysis.
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.