Brown v. United States
Headline: Court rules that prior state drug convictions count toward ACCA if the drug was on federal schedules when the state crime occurred, preserving 15‑year mandatory minimums for some felon‑in‑possession defendants.
Holding: The Court held that a prior state drug conviction qualifies as an ACCA predicate if the drug was listed on the federal schedules when the defendant committed the state offense.
- Keeps 15‑year ACCA minimum for qualifying state drug priors.
- Requires courts to check federal drug schedules in effect when the state crime occurred.
- May increase historical research for sentencing in felon‑in‑possession cases.
Summary
Background
Two men convicted of possessing a gun after felony convictions—Justin Rashaad Brown and Eugene Jackson—challenged enhanced federal sentences. Each had earlier state drug convictions that matched the federal drug lists when those state crimes occurred. Later changes to the federal drug schedules (an agricultural exemption for some hemp and the removal of a radioactive cocaine derivative) meant the federal and state definitions no longer matched by the time of their federal cases, so they argued those prior state convictions should not count for a 15‑year mandatory minimum under the Armed Career Criminal Act (ACCA).
Reasoning
The Court asked whether the federal and state drug definitions must match when the state crime happened, when the defendant committed the federal gun offense, or when the federal sentence was imposed. Relying on prior cases and ACCA’s text, the Court adopted a backward‑looking approach: a state drug conviction counts as an ACCA predicate if the drug was on the federal schedules at the time of that state offense. The Court explained that ACCA measures a defendant’s past criminal history to assess dangerousness, that § 924(e)(2)(A)(i) treats offenses “under the [CSA]” as predicates, and that later changes to federal schedules do not erase an earlier conviction’s relevance.
Real world impact
The ruling means many defendants with old state drug convictions will still face ACCA’s 15‑year minimum if the drug was federally scheduled when their state offense occurred. Sentencing courts must sometimes consult historical federal schedules to decide ACCA eligibility. The decision was a merits ruling affirming the courts of appeals.
Dissents or concurrances
Justice Jackson (joined by Justice Kagan, and partly by Justice Gorsuch) dissented, arguing that the cross‑reference to the federal drug definition requires using the federal schedules in effect when the federal gun offense occurred, and that the text and ordinary operation of cross‑references support that view.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?