Chambers v. United States
| Chambers v. United States | |
|---|---|
 | |
| Argued November 10, 2008 Decided January 13, 2009 | |
| Full case name | Deondery Chambers, Petitioner v. United States |
| Docket no. | 06-11206 |
| Citations | 555 U.S. 122 (more) 129 S. Ct. 687; 172 L. Ed. 2d 484; 2009 U.S. LEXIS 580 |
| Case history | |
| Prior | United States v. Chambers, 473 F.3d 724 (7th Cir. 2007); cert. granted, 553 U.S. 1003 (2008). |
| Holding | |
| Failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act. | |
| Court membership | |
| |
| 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.C. §§ 924–e) | |
Chambers v. United States, 555 U.S. 122 (2009),[1] was a 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.[2]
Background
[edit]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, pleaded 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."[3]
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.[4] 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),[5] while the Ninth Circuit held that it did not in United States v. Piccolo (2006).[6] The Supreme Court granted certiorari to resolve the split.
Opinion of the Court
[edit]Robert Hochman argued the case for the petitioner. Assistant to the Solicitor General Matthew D. Roberts argued for the respondent.[7] 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.[7]
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.
References
[edit]- ^ Chambers v. United States, 555 U.S. 122 (2009).
- ^ .
- ^ Quoted in Chambers v. United States, 555 U.S. at 690.
- ^ United States v. Chambers, 473 F.3d 724 (7th Cir. 2007).
- ^ United States v. Winn, 364 F.3d 7 (1st Cir. 2001).
- ^ United States v. Piccolo, 441 F.3d 1084 (9th Cir. 2006).
- ^ a b "Chambers v. United States". Oyez.
External links
[edit]- Text of Chambers v. United States, 555 U.S. 122 (2009) is available from: Cornell CourtListener Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)