Burgess v. United States

Background

Keith Lavon Burgess, a federal defendant, pleaded guilty to conspiring to distribute 50 grams or more of cocaine base. He had a prior South Carolina possession conviction that carried up to two years but was labeled a misdemeanor under state law. The federal Government sought to double the mandatory minimum sentence from ten to twenty years under federal law because the prior conviction was punishable by more than one year. Burgess argued the enhancement should apply only if the prior offense was classified as a felony by the state and punishable by more than one year. The district court and the Fourth Circuit applied only the federal statute’s definition based on punishability; the Supreme Court granted review to settle a split among circuit courts.

Reasoning

The Court addressed whether the term 'felony drug offense' incorporates a separate definition of 'felony' or is defined only by the statute’s specific phrase. The justices held that Congress’ separate definition of 'felony drug offense'—an offense punishable by more than one year—controls. The Court relied on the statutory text, structure, and Congress’s 1994 revision adopting a uniform federal standard, and rejected application of the rule of lenity because the definition is clear. As a result, the Government prevailed and the twenty-year enhancement can apply.

Real world impact

The ruling means prior state drug convictions that carry more than one year’s potential imprisonment can trigger harsher federal mandatory minimums even if states call them misdemeanors. The decision creates a uniform federal test based on punishment length and resolves differing circuit approaches.