| Chambers v. United States | ||||||
|---|---|---|---|---|---|---|
Supreme Court of the United States |
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| Full case name | Chambers v. United States | |||||
| Docket nos. | 6-11206 | |||||
| Holding | ||||||
| Failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Breyer, joined by Roberts, Stevens, Scalia, Kennedy, Souter, Ginsburg | |||||
| Concurrence | Alito, joined by Thomas | |||||
| Laws applied | ||||||
| Armed Career Criminal Act (18 U.S. 924 (e)) | ||||||
Chambers v. United States, No. 06-11206 (2008),[1] was a recent case in which the Supreme Court of the United States held that failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act (18 U.S. 924 (e)).
Contents |
The Armed Career Criminal Act, enacted in 1984 and since amended, provides for enhanced sentences for felons who commit crimes with firearms. A felon convicted of a "violent felony" or a "serious drug offense" at least three times faces a minimum sentence of fifteen years in prison.
The petitioner, Deondery Chambers, pled guilty in District Court to the charge of being a felon in unlawful possession of a firearm. The prosecution sought to invoke the ACCA's mandatory 15-year prison term on the grounds that Chambers had three prior convictions which qualified: robbery and aggravated battery (1998), a drug conviction (1999), a failure to report for incarceration charge stemming from the robbery and battery conviction. The court had required Chambers to report to a local prison for 11 weekends of incarceration; Chambers missed four of the weekends and was convicted under Illinois law for "fail[ing] to report to a penal institution."[1]
Chambers challenged the failure to report, arguing that it was not a "violent felony." The District Court disagreed, treating the failure to report as similar to an escape and therefore a violent felony under the ACCA. The United States Court of Appeals for the Seventh Circuit upheld the District Court. Other Courts of Appeal had come to differing conclusions: the First Circuit agreed that failure to report qualified as a violent felony in United States v. Winn (2001), while the Ninth Circuit held that it did not in United States v. Piccolo (2006).[2] The Supreme Court granted certiorari to resolve the split.
Robert Hochman argued the case for the petitioner. Assistant to the Solicitor General Matthew D. Roberts argued for the respondent[3]. Roberts argued that "failure-to-report escape is similar in kind to burglary because it's purposeful, violent, and aggressive in the same way as burglary." Roberts argued that failure to report is an invitation for a violent confrontation between the police and the felon[4].
The Supreme Court held unanimously that a failure to report did not qualify as a violent felony for the purposes of the Armed Career Criminal Act. Justice Breyer wrote the majority opinion which six other justices joined, while Justice Alito wrote a concurrence which Justice Thomas joined.