Johnson v. United States

Background

A man with a long criminal record pleaded guilty to being a felon in possession of a firearm. The Government sought a higher mandatory sentence under the Armed Career Criminal Act (ACCA) because he had three earlier felony convictions, including unlawful possession of a short-barreled shotgun under Minnesota law. Lower courts treated that shotgun conviction as a qualifying “violent felony” under ACCA’s so‑called residual clause, and the defendant received a 15‑year minimum sentence.

Reasoning

The Court examined the residual clause, which defines a violent felony to include crimes that “otherwise involve conduct that presents a serious potential risk of physical injury to another.” The majority found the clause hopelessly indeterminate. Judges must imagine the “ordinary case” of countless crimes and then assess speculative risks; prior opinions used inconsistent tests and lower courts are widely split. That combination, the Court held, denies ordinary people fair notice and invites arbitrary enforcement. The Court therefore ruled the residual clause unconstitutional under the Fifth Amendment and overruled parts of earlier decisions that had upheld it.

Real world impact

As a result, courts may no longer impose ACCA’s enhanced 15‑year‑to‑life sentences based solely on the residual clause. The ruling leaves the statute’s enumerated categories (like burglary, arson, extortion, and offenses involving explosives) intact but requires reexamination of cases where enhancements relied only on the vague clause. The case is returned to the lower court for further proceedings consistent with this opinion.

Dissents or concurrances

Two concurring Justices agreed the sentence must be vacated but differed on reasoning. A dissent argued the clause is workable, defended stare decisis, and maintained that possession of a sawed‑off shotgun typically poses serious risk and qualifies for enhancement.