Muscarello v. United States

Background

A man who sold marijuana drove to a sale with a handgun locked in his truck’s glove compartment. In a separate case, two men packed guns in a bag, placed the bag in a car trunk, and drove to a planned drug-related meeting. Each was charged under a federal law that adds a five-year mandatory prison term when someone “uses or carries a firearm” during a drug trafficking crime. The legal question was whether “carries a firearm” only means carrying a gun on one’s person.

Reasoning

The majority looked at ordinary English usage, dictionaries, examples from literature and newspapers, Congress’s purpose, and related firearm statutes. The Court concluded that “carry” in its common sense can mean conveying or transporting a weapon in a vehicle that the person accompanies. The Court emphasized that the statute’s words “during and in relation to” limit prosecutions to cases where the gun is connected to the drug crime. Based on this interpretation, the Court affirmed the lower courts and held that guns in a locked glove compartment or trunk can count as “carried.”

Real world impact

People who knowingly place firearms in vehicles in connection with drug offenses can be sentenced under the statute’s five-year mandatory minimum. The decision thus expands the situations that trigger the enhanced penalty and affects sentencing outcomes for defendants caught with guns in cars. The ruling affirms the appellate judgments before the Court.

Dissents or concurrances

The dissent would have read “carries” more narrowly — limited to guns on or about the person — citing prior cases, sentencing guidelines, and the rule of lenity. The dissent feared the majority’s reading produces harsher mandatory sentences where Congress did not clearly say so.