In the case of Arnold F. Hohn v. United States in 1997, the Supreme Court ruled on whether a defendant's prior conviction for conspiracy to commit a crime could be used as an enhancement under the Armed Career Criminal Act (ACCA). The ACCA imposes a mandatory minimum sentence of 15 years for defendants who have three previous convictions for violent felonies or serious drug offenses. Hohn argued that his previous conviction should not count because it was not specifically listed in the ACCA statute and therefore did not qualify as a predicate offense. The Supreme Court disagreed with Hohn's argument, ruling unanimously that his prior conviction did indeed qualify him for sentencing under ACCA. They reasoned that while conspiracy is not explicitly mentioned in the statute, it is implicitly included within its scope due to being similar in kind and degree of risk posed by other offenses listed therein. This decision clarified how courts interpret what constitutes "violent felony" or "serious drug offense" when applying enhanced sentences under federal law.

In the dissenting opinion for Arnold F. Hohn v. United States, Justice Stevens argued that the majority's interpretation of 18 U.S.C § 3742(a) was incorrect and overly restrictive. He contended that a defendant should be able to appeal their sentence if they believe it is inconsistent with federal guidelines, even if it falls within an acceptable range set by those guidelines. According to him, this would ensure fairness in sentencing and prevent potential abuses of discretion by district courts. Furthermore, he disagreed with the majority's view that allowing such appeals would lead to excessive litigation or undermine judicial efficiency; instead, he believed it could promote greater consistency in sentencing practices across different jurisdictions.