Term: 2016
Docket: 15-8544
Beckles v. United States
- Pro
15-8544 BECKLES V. UNITED STATES DECISION BELOW: 616 Fed.Appx. 415 JUSTICE KAGAN TOOK NO PART. ORDER OF AUGUST 11, 2016: ADAM K. MORTARA, ESQUIRE, OF CHICAGO, ILLINOIS, IS INVITED TO BRIEF AND ARGUE THIS CASE, AS AMICUS CURIAE, IN SUPPORT OF THE JUDGMENT BELOW ON QUESTION 2 PRESENTED BY THE PETITION. CERT. GRANTED 6/27/2016 QUESTION PRESENTED: Johnson v. United States, 135 S. Ct. 2551 (2015), deemed unconstitutionally vague the residual clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(ii) (defining "violent felony"). The residual clause invalidated in Johnson is identical to the residual clause in the career-offender provision of the United States Sentencing Guidelines, U.S.S.G. § 4B1.2(a)(2) (defining "crime of violence"). The questions presented are: 1. Whether Johnson applies retroactively to collateral cases challenging federal sentences enhanced under the residual clause in U.S.S.G. § 4B1.2(a)(2)? 2. Whether Johnson's constitutional holding applies to the residual clause in U.S.S.G. § 4B1.2(a) (2), thereby rendering challenges to sentences enhanced under it cognizable on collateral review? 3. Whether mere possession of a sawed-off shotgun, an offense listed as a "crime of violence" only in the commentary to U.S.S.G. § 4B1.2, remains a "crime of violence" after Johnson? LOWER COURT CASE NUMBER: 13-13569
In the case of Beckles v. United States, Travis Beckles was convicted for illegal possession of a firearm in 2007 and sentenced under the U.S. Sentencing Guidelines which were advisory rather than mandatory at that time. He appealed his sentence, arguing it was unconstitutionally vague based on the Supreme Court's ruling in Johnson v. United States (2015) which invalidated a similar clause in another law as being too vague. The question before the court was whether or not these guidelines could be challenged for vagueness under due process principles established by previous rulings such as Johnson v. United States (2015). In March 2017, the Supreme Court ruled unanimously against Beckles stating that unlike laws prescribing minimum and maximum sentences, sentencing guidelines do not fix punishments but merely guide judges' discretion within certain limits set by Congress; therefore they cannot be held to standards of precision applicable to criminal statutes.
In the dissenting opinion for Beckles v. United States, Justice Sotomayor argued that the advisory sentencing guidelines should be subject to vagueness challenges under the Due Process Clause. She contended that these guidelines have a significant influence on judges' decisions and can lead to unjust sentences if they are vague or unclear. Furthermore, she believed that allowing defendants to challenge these guidelines would promote fairness in sentencing and uphold constitutional principles of due process. In her view, failing to allow such challenges could result in arbitrary enforcement of criminal laws and undermine public confidence in the justice system.
