Custis v. United States

1994-05-23

Headline: Court upholds rule barring most challenges to prior state convictions used to trigger long mandatory sentences under the career‑offender gun law, except for convictions obtained without counsel, limiting defendants’ contesting options.

Holding: A defendant may not collaterally attack prior state convictions at a federal ACCA sentencing proceeding, except for prior convictions obtained in violation of the right to counsel.

Real World Impact:

Blocks most challenges to old state convictions during federal sentencing, except uncounseled convictions.
Leaves defendants to pursue state or federal habeas relief before seeking reduced federal sentence.
Shortens sentencing inquiries but may sustain longer mandatory federal terms.

Topics: gun sentencing, prior convictions, sentence enhancement, right to counsel, habeas review

Summary

Background

Darren Custis was arrested and federally charged with drug and firearms offenses. The Government sought a harsh mandatory sentence under the Armed Career Criminal Act by relying on three prior state felony convictions: a 1985 Pennsylvania robbery, a 1985 Maryland burglary, and a 1989 Maryland attempted burglary. Custis was convicted of possession of a firearm and a lesser cocaine offense. At sentencing the Government asked for enhancement under §924(e); Custis tried to challenge two Maryland convictions as constitutionally flawed, citing ineffective counsel, an unknowing guilty plea, and a stipulated‑facts trial.

Reasoning

The Court framed the central question as whether a defendant may attack earlier state convictions during a federal sentencing under the ACCA. The majority read §924(e) as focusing on the fact of conviction and noted related statutes that expressly allow challenges when Congress intended them. The Court held that the Constitution permits collateral attack at sentencing only when a prior conviction was obtained without counsel; other claims like ineffective assistance or an unknowing plea do not qualify. Practical concerns — records, finality, comity, and administrative burden — also supported the rule.

Real world impact

As a result, defendants facing ACCA enhancements generally may not relitigate most constitutional claims about old state convictions at the federal sentencing hearing. The opinion confirms that Custis’ sentence was properly enhanced and affirmed the lower courts’ rulings. The Court noted that a defendant still in custody for the state conviction can attack it in state court or by federal habeas, and if successful may seek reopening of the federal sentence.

Dissents or concurrances

Justice Souter (joined by Justices Blackmun and Stevens) dissented, arguing the statute should be read to allow challenges to unlawfully obtained prior convictions, citing appellate practice, lenity, and judicial restraint principles.