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Beckles v. United States

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Supreme Court of the United States
Beckles v. United States
Reference: 15-8544
Issue: Criminal procedure
Term: 2016
Important Dates
Argued: November 28, 2016
Decided: March 6, 2017
Outcome
Eleventh Circuit Court of Appeals affirmed
Vote
7-0 to affirm; Kagan recused
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor
Concurring
Kennedy
Ginsburg concurring in the judgment
Sotomayor concurring in the judgment
Dissenting
None


Beckles v. United States is a case that was argued during the October 2016 term of the U.S. Supreme Court. Argument in the case was held on November 28, 2016. On March 6, 2017, in an opinion by Justice Clarence Thomas, the court unanimously affirmed the judgment of the Eleventh Circuit Court of Appeals. Justice Elena Kagan took no part in the consideration or disposition of the case.[1]

HIGHLIGHTS
  • The case: After being ordered to review a judgment against Travis Beckles in light of the U.S. Supreme Court's 2014 ruling in Johnson v. United States, the Eleventh Circuit affirmed that Beckles' conviction for unlawful possession of a sawed-off shotgun was a crime of violence and that he was properly sentenced as a career offender under the U.S. Sentencing Guidelines.
  • The issue: Does the Supreme Court's decision in Johnson control for crimes defined as crimes of violence under the U.S. Sentencing Guidelines?
  • The outcome: The court unanimously affirmed the judgment of the Eleventh Circuit Court of Appeals.


    • In brief: In 2015, the U.S. Supreme Court held in Johnson v. United States that the language of the Armed Career Criminal Act's (ACCA) residual clause defining violent felony was unconstitutionally vague. That clause defined violent felony, in part, as a crime where conduct that presents a serious potential risk of physical injury to another was present. Travis Beckles was convicted of a crime constituting a crime of violence under the U.S. Sentencing Guidelines. The guidelines define crime of violence, in part, as a crime that otherwise involves conduct that presents a serious potential risk of physical injury to another.[2] Beckles argued that this language is substantively similar, and as unconstitutionally vague, as the language in the ACCA that was struck down in Johnson. The government rejected that claim. Oral argument in the case was held on November 28, 2016. On March 6, 2017, in an opinion by Justice Clarence Thomas, the court unanimously affirmed the judgment of the Eleventh Circuit Court of Appeals. Justice Elena Kagan took no part in the consideration or disposition of the case.

    You can review the Eleventh Circuit's opinion here.[3]

    Click on the tabs below to learn more about this Supreme Court case.

    Case


    Background

    Travis Beckles had two previous convictions for drug-related offenses when he was convicted for unlawful possession of a sawed-off shotgun. §4B1.2 of the U.S. Sentencing Guidelines defines crime of violence, in part, as a crime that otherwise involves conduct that presents a serious potential risk of physical injury to another. According to note #1 in the commentary under §4B1.2 of the guidelines, "Unlawfully possessing a firearm described in 26 U.S.C. § 5845(a) (e.g., a sawed-off shotgun or sawed-off rifle, silencer, bomb, or machine gun) is a 'crime of violence.'"[2] Based on the guidelines' definition of crime of violence, the inclusion in the commentary that unlawful possession of a sawed-off shotgun constituted a crime of violence, and his previous convictions, the district court sentenced Beckles as a career offender under the guidelines.[3]

    Beckles moved to vacate his sentence. He alleged that he was improperly sentenced as a career offender because unlawful possession of a sawed-off shotgun was not a crime of violence. The district court denied his motion and the United States Court of Appeals for the 11th Circuit affirmed, relying on that court's holding in United States v. Hall that possession of an unregistered sawed-off shotgun qualified as a "crime of violence" under the Sentencing Guidelines.[4] In 2015, the U.S. Supreme Court issued its decision in Johnson v. United States, holding the Armed Career Criminal Act's (ACCA) residual clause defining violent felony to be unconstitutionally vague. That clause defined violent felony, in part, as a crime where conduct that presents a serious potential risk of physical injury to another was present. In evaluating the Sentencing Guidelines' definition of crime of violence and ACCA's residual clause definition of violent felony, the Supreme Court subsequently vacated the Eleventh Circuit's decision in Beckles' case and remanded the case back to the circuit court for evaluation of Beckles' claim in light of the court's ruling in Johnson.[3]

    On remand, the Eleventh Circuit affirmed the district court's denial of Beckles' motion to vacate his sentence. The circuit court held Johnson did not control Beckles' appeal because[3]

    “

    the Supreme Court's decision in Johnson -- in which the Supreme Court struck down, as unconstitutionally vague, the residual clause of the Armed Career Criminal Act ("ACCA") -- does not control this appeal ... Johnson says and decided nothing about career-offender enhancements under the Sentencing Guidelines or the Guidelines commentary underlying Beckles's status as a career-offender. [5]

    		”

    Beckles appealed to the U.S. Supreme Court.

    Petitioner's challenge

    Travis Beckles claimed that the language under §4B1.2 of the U.S. Sentencing Guidelines defining crime of violence was substantively similar, and as unconstitutionally vague, as the language in the Armed Career Criminal Act's (ACCA) residual clause defining violent felony - language that was struck down by the U.S. Supreme Court in Johnson v. United States.

    Certiorari granted

    On March 9, 2016, Travis Beckles, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the United States Court of Appeals for the 11th Circuit. The U.S. Supreme Court granted Beckles' certiorari request on June 27, 2016. Oral argument in the case was held on November 28, 2016. Justice Elena Kagan took no part in the decision to grant certiorari in this case.[1]

    Arguments


    Questions presented

    Questions presented:

    "*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?[1]


    Audio

    • Audio of oral argument:[6]



    Transcript

    • Transcript of oral argument:[7]

    Outcome


    Decision

    In a unanimous decision, the Supreme Court affirmed the decision of the Eleventh Circuit Court of Appeals. Justice Clarence Thomas delivered the opinion of the court. Justice Anthony Kennedy authored a concurring opinion. Justice Ruth Bader Ginsburg and Justice Sonia Sotomayor each wrote opinions concurring in the judgment. Justice Elena Kagan took no part in the consideration or disposition of the case.[8]

    Opinion

    In his opinion for the court, Justice Thomas clarified the key distinction between the language at issue in this case and the language the court found unconstitutionally vague in Johnson v. United States,[8]

    “

    This Court has held that the Due Process Clause prohibits the Government from 'taking away someone’s life, liberty, or property under a criminal law so vague that it fails to give ordinary people fair notice of the conduct it punishes, or so standardless that it invites arbitrary enforcement.' ... Applying this standard, the Court has invalidated two kinds of criminal laws as 'void for vagueness': laws that define criminal offenses and laws that fix the permissible sentences for criminal offenses. For the former, the Court has explained that 'the void-for-vagueness doctrine requires that a penal statute define the criminal offense with sufficient definiteness that ordinary people can understand what conduct is prohibited and in a manner that does not encourage arbitrary and discriminatory enforcement.' ... For the latter, the Court has explained that 'statutes fixing sentences,' ... must specify the range of available sentences with 'sufficient clarity,' ... In Johnson, we applied the vagueness rule to a statute fixing permissible sentences. The ACCA’s residual clause, where applicable, required sentencing courts to increase a defendant’s prison term from a statutory maximum of 10 years to a minimum of 15 years. That requirement thus fixed—in an impermissibly vague way—a higher range of sentences for certain defendants. ... Unlike the ACCA, however, the advisory Guidelines do not fix the permissible range of sentences. To the contrary, they merely guide the exercise of a court’s discretion in choosing an appropriate sentence within the statutory range. Accordingly, the Guidelines are not subject to a vagueness challenge under the Due Process Clause. The residual clause in §4B1.2(a)(2) therefore is not void for vagueness. [5]

    		”

    In interpreting the federal sentencing guidelines as advisory only and not as a sentence-fixing statute, the court held that the guidelines are not subject to a vagueness challenge under the due process clause of the 14th Amendment. The court rejected Beckles' vagueness challenge and affirmed the judgment of the Eleventh Circuit Court of Appeals.

    Concurring opinions

    Justice Anthony Kennedy wrote a concurring opinion in which he outlined his understanding of the term vague as applied to law. In his words, "that something is vague as a general matter, however, does not necessarily mean that it is vague within the well-established legal meaning of that term. And it seems most unlikely that the definitional structure used to explain vagueness in the context of fair warning to a transgressor, or of preventing arbitrary enforcement, is, by automatic transference, applicable to the subject of sentencing where judicial discretion is involved as distinct from a statutory command. ... The existing principles for defining vagueness cannot be transported uncritically to the realm of judicial discretion in sentencing. Some other explication of the constitutional limitations likely would be required."[8]

    Justice Ruth Bader Ginsburg wrote an opinion concurring in the judgment only. Her opinion was brief and is presented in its entirety below (citations and footnotes omitted):[8]

    “

    This case has a simple solution. When Travis Beckles was convicted in 2007 of violating 18 U. S. C. §922(g)(1),the official commentary to the career-offender Sentencing Guideline expressly designated his offense of conviction—possessing a sawed-off shotgun as a felon—a 'crime of violence.' ... Harmonious with federal law and the text of §4B1.2(a), that commentary was 'authoritative.' ... Beckles therefore cannot, and indeed does not, claim that §4B1.2(a) was vague as applied to him. And because his conduct was 'clearly proscribed,' he also 'cannot complain of the vagueness of the [guideline] as applied to the conduct of others.' ... I would accordingly defer any more encompassing ruling until a case we have agreed to take up requires one. [5]

    		”

    Justice Sonia Sotomayor wrote an opinion concurring in the judgment only. In her view, the court's opinion exceeded the scope of what was necessary to decide the case. Justice Sotomayor wrote, "Johnson affords Beckles no relief, because the commentary under which he was sentenced was not unconstitutionally vague. Had the majority limited itself to this conclusion, I would have joined its opinion. Instead, the majority reaches far beyond what is necessary to resolve this case and announces that the U.S. Sentencing Guidelines as a whole are immune from vagueness challenges. I write separately to explain why that holding is not only unnecessary, but also deeply unsound. ... It violates the Due Process Clause 'to condemn someone to prison' on the basis of a sentencing rule 'so shapeless' as to resist interpretation. ... But the Court’s decision today permits exactly that result. With respect, I concur only in the judgment."[8]

    Dissenting opinions

    There were no dissenting opinions filed.

    The opinion

    Filings

    The court granted Beckles' certiorari request on June 27, 2016.

    Merits filings

    Parties' filings

    • Travis Beckles, the petitioner, filed a merits brief on August 11, 2016.
    • The United States of America, the respondent, filed a merits brief on September 19, 2016.
    • Beckles filed a reply brief on the merits on November 17, 2016.
    • The United States of America filed a reply brief on the merits on November 21, 2016.

    Amicus curiae filings

    The following groups filed an amicus curiae brief in support of the petitioner, Travis Beckles.

    • Brief of the National Association of Federal Defenders and various federal public and community defenders
    • Brief of various scholars of criminal law, federal courts, and sentencing


    The court appointed an amicus curiae, who filed a brief in support of the judgment below on question 2 of the petition for certiorari.

    • Brief of the court-appointed amicus curiae

    Certiorari filings

    Parties' filings

    • Travis Beckles, the petitioner, filed a petition for certiorari on March 9, 2016.
    • The United States of America, the respondent, filed a brief in opposition to certiorari on May 13, 2016.

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, Beckles v. United States, June 27, 2016
    2. ↑ 2.0 2.1 U.S. Sentencing Commission, "§4B1.2," accessed September 25, 2016
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Court of Appeals for the Eleventh Circuit, Travis Beckles v. United States of America, decided September 29, 2015
    4. ↑ U.S. Court of Appeals for the Eleventh Circuit, "United States v. Hall," decided 2013
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, Beckles v. United States, argued November 28, 2016
    7. ↑ Supreme Court of the United States, Beckles v. United States, argued November 28, 2016
    8. ↑ 8.0 8.1 8.2 8.3 8.4 Supreme Court of the United States, Beckles v. United States, decided March 6, 2017
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