Term: 2007
Docket: 06-571
Michael A. Watson v. United States
- Pro
06-571 WATSON V. UNITED STATES DECISION BELOW: 191 Fed. Appx. 326 CERT. GRANTED 2/26/2007 QUESTION PRESENTED: 18 U.S.C. § 924(c)(1)(A) criminalizes the “use” of a firearm during and in relation to a drug trafficking offense and imposes a mandatory consecutive sentence of at least five years’ imprisonment. In Bailey v. United States, 516 U.S. 137 (1995), this Court held that “use” of a firearm under § 924(c) means “active employment.” Id. at 144. The question presented in this case is: Whether mere receipt of an unloaded firearm as payment for drugs constitutes “use” of the firearm during and in relation to a drug trafficking offense within the meaning of 18 U.S.C. § 924(c)(l)(A) and this Court’s decision in Bailey. LOWER COURT CASE NUMBER: 05-31094
In the case of Michael A. Watson v. United States in 2007, the Supreme Court ruled that a person who trades drugs for a gun is not "using" a firearm under federal law. The court unanimously overturned Watson's conviction on charges of using a firearm during drug trafficking, which carries an additional five-year prison term beyond his sentence for drug dealing and possession of illegal weapons. The ruling clarified that receiving a gun in trade for drugs does not constitute "use" as defined by 18 U.S.C §924(c). This decision was based on the interpretation that “use” implies active employment of the firearm, and merely trading it doesn't meet this definition.
In the dissenting opinion for Michael A. Watson v. United States, Justice Souter argued that a person who trades drugs for a gun should not be considered to "use" the firearm in relation to drug trafficking under 18 U.S.C §924(c)(1). He contended that this interpretation of the statute was inconsistent with its language and purpose. The majority's reading, he said, would lead to absurd results where someone could be punished more severely for trading drugs for an unloaded antique firearm than they would be if they had used a modern loaded weapon during a violent crime. This contradicts Congress' intent when it enacted §924(c)(1), which was designed to deter people from using firearms in connection with drug trafficking crimes by imposing harsher penalties on those who do so.
