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Brown v. United States

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Supreme Court of the United States
Brown v. United States
Term: 2023
Important Dates
Argued: November 27, 2023
Decided: May 23, 2024
Outcome
Affirmed
Vote
6-3
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Ketanji Brown Jackson • Elena Kagan • Neil Gorsuch

Brown v. United States is a case that was decided by the Supreme Court of the United States on May 23, 2024, during the court's October 2023-2024 term. It was consolidated with Jackson v. United States. The case was argued before the Supreme Court of the United States on November 27, 2023.

In a 6-3 opinion, the court affirmed the judgment of the United States Court of Appeals for the Third Circuit, holding that a state drug conviction counts as an Armed Career Criminal Act (ACCA) predicate if it involved a drug on the federal schedules at the time of that offense.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned the Armed Career Criminal Act's definition of a serious drug offense. Click here to learn more about the case's background.
  • The questions presented: "Whether the serious drug offense definition in the Armed Career Criminal Act,18 U.S.C. § 924(e)(2)(A)(ii), incorporates the federal drug schedules that were in effect at the time of the federal firearm offense (as the Third, Fourth, Eighth, and Tenth Circuits have held), or the federal drug schedules that were in effect at the time of the prior state drug offense."[2] Brown v. United States also asks "[w]hich version of federal law should a sentencing court consult under ACCA's categorical approach?"[3]
  • The outcome: In a 6-3 opinion, the court affirmed the judgment of the United States Court of Appeals for the Third Circuit, holding that a state drug conviction counts as an Armed Career Criminal Act (ACCA) predicate if it involved a drug on the federal schedules at the time of that offense. Justice Samuel Alito delivered the opinion of the court.[1]


    • Brown v. United States came on a writ of certiorari to the United States Court of Appeals for the Third Circuit. Click here to review the lower court's opinion.

    Jackson v. United States came on a writ of certiorari to the United States Court of Appeals for the Eleventh Circuit. Click here to review the lower court's opinion.

    Timeline

    The following timeline details key events in Brown v. United States:

    The following timeline details key events in Jackson v. United States:

    Background

    Brown v. United States and Jackson v. United States are consolidated cases involving the Armed Career Criminal Act (ACCA). The Court was asked to determine whether the definition of a serious drug offense in the Armed Career Criminal Act 18 U.S.C. § 924(e)(2)(A)(ii), includes the federal drug schedules that were in effect at the time of the federal firearm offense. The Court is also asked which version of federal law a sentencing court should consult when applying the ACCA's categorical approach.[4]

    In 2016, police officers found cocaine, scales, and a loaded firearm in Justin Rashaad Brown's home during a warrant-authorized search. On July 8, 2019, the Middle District of Pennsylvania accepted Brown's guilty plea to one count of drug distribution and one count of felon-in-possession. The Probation Office recommended that Brown be sentenced under the ACCA due to his five prior convictions, one for delivering cocaine and four for possession of marijuana with intent to deliver. The petitioner objected to the recommendation. He argued that his marijuana convictions did not match the federal definition because the Agricultural Improvement Act of 2018 excludes hemp from the federal definition of marijuana. Pennsylvania’s definition of marijuana does not exclude hemp and is broader than the federal definition.[5][6]

    Armed Career Criminal Act 18 U.S.C. § 924(e)

    According to the Armed Career Criminal Act[7]:

    “ (e)(1) In the case of a person who violates section 922(g) of this title and has three previous convictions by any court referred to in section 922(g)(1) of this title for a violent felony or a serious drug offense, or both, committed on occasions different from one another, such person shall be fined under this title and imprisoned not less than fifteen years, and, notwithstanding any other provision of law, the court shall not suspend the sentence of, or grant a probationary sentence to, such person with respect to the conviction under section 922(g).

    (2) As used in this subsection--

    (A) the term “serious drug offense” means--

    (i) an offense under the Controlled Substances Act (21 U.S.C. 801 et seq.), the Controlled Substances Import and Export Act (21 U.S.C. 951 et seq.), or chapter 705 of title 46, for which a maximum term of imprisonment of ten years or more is prescribed by law;  or

    (ii) an offense under State law, involving manufacturing, distributing, or possessing with intent to manufacture or distribute, a controlled substance (as defined in section 102 of the Controlled Substances Act (21 U.S.C. 802)), for which a maximum term of imprisonment of ten years or more is prescribed by law.[8]

    		”

    Questions presented

    The petitioner presented the following questions to the court:[2][3]

    Questions presented in Brown v. United States:
    “

    Whether the "serious drug offense" definition in the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(A)(ii), incorporates the federal drug schedules that were in effect at the time of the federal firearm offense (as the Third, Fourth, Eighth, and Tenth Circuits have held), or the federal drug schedules that were in effect at the time of the prior state drug offense (as the Eleventh Circuit held below). [8]

    		”


    Questions presented in Jackson v. United States:
    “

    Which version of federal law should a sentencing court consult under ACCA's categorical approach? [8]

    		”

    Oral argument

    Audio

    Audio of oral argument:[9]




    Transcript

    Transcript of oral argument:[10]

    Outcome

    In a 6-3 opinion, the court affirmed the judgment of the United States Court of Appeals for the Third Circuit, holding that a state drug conviction counts as an Armed Career Criminal Act (ACCA) predicate if it involved a drug on the federal schedules at the time of that offense. Justice Samuel Alito delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Samuel Alito wrote:[1]

    “

    Precedent and statutory context support the Government’s interpretation. ACCA gauges what a defendant’s ‘history of criminal activity’ says about his or her ‘culpability and dangerousness.’ McNeill v. United States, 563 U. S. 816, 823. In previous cases, the Court has held that ACCA requires sentencing courts to examine the law as it was when the defendant violated it. This ‘backward-looking’ approach, id., at 820, supports the Government’s interpretation. And the plain language of the statute points to the same conclusion. Section 924(e)(2)(A)(i), which immediately precedes the provision at issue, defines a ‘serious drug offense’ to include, among other things, ‘offense[s] under the Controlled Substances Act.’ A later change in a federal drug schedule does not change the fact that an offense ‘under the [CSA]’ is a ‘serious drug offense.’ The Government’s interpretation would treat state offenses ‘involving . . . a controlled substance (as defined in [the CSA])’ like those federal offenses ‘under the [CSA].’ Petitioners’ interpretations, by contrast, would treat those federal and state offenses differently, i.e., the federal offense would remain an ACCA predicate, but the state offense would not.[8]

    		”
    —Justice Samuel Alito

    Dissenting opinion

    Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justices Elena Kagan and Neil Gorsuch as to Parts I, II, and III.

    In her dissent, Justice Jackson wrote:[1]

    “

    The majority’s contrary holding seems to reflect its own policy view that ‘Brown’s and Jackson’s multiple convictions’ pose a significant risk of future dangerousness ‘despite the technical changes to the federal drug schedules.’ Ante, at 11. But the choice of how to assess and address dangerousness belongs first and foremost to Congress. And for the reasons I have explained, Congress designed ACCA to take a different approach—to measure future dangerousness by today’s drug schedules, not outdated ones from the past. See Part I, supra. One might harbor doubts that the sentencing policy that Congress enacted is sensible, just, or effective. But it is the one that Congress wrote, and we remain dutybound to apply the law as written. In my view, the majority has failed to do so here.[8]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, "Brown v. United States", decided May 23, 2024
    2. ↑ 2.0 2.1 SupremeCourt.gov, "22-6640 JACKSON V. UNITED STATES," accessed May 15, 2023
    3. ↑ 3.0 3.1 SupremeCourt.gov, "22-6389 BROWN V. UNITED STATES," accessed May 15, 2023
    4. ↑ "SCOTUSblog", "Congressional redistricting, patent infringement, arbitration, and the Armed Career Criminal Act," May 11, 2023
    5. ↑ THE SUPREME COURT OF THE UNITED STATES, "ON PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT," March 24, 2023
    6. ↑ THE SUPREME COURT OF THE UNITED STATES, "JUSTIN RASHAAD BROWN v. UNITED STATES OF AMERICA, On Petition for a Writ of Certiorari to the United States Court of Appeals for the Third Circuit," December 21, 2022
    7. ↑ U.S. Code, "18 U.S.C. § 924 - U.S. Code - Unannotated Title 18. Crimes and Criminal Procedure § 924. Penalties," accessed May 23, 2023
    8. ↑ 8.0 8.1 8.2 8.3 8.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 27, 2023
    10. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 27, 2023
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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