Quimbee logo
DMCA.com Protection Status
From our private database of 16,300+ case briefs...

Lockhart v. United States

United States Supreme Court
136 S. Ct. 958 (2016)


Facts

Avondale Lockhart (defendant) was convicted of possessing child pornography. Lockhart previously had been convicted of sexually assaulting his adult girlfriend. 18 U. S. C. § 2252(b)(2) stated that anyone who has been convicted of aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor shall be imprisoned for at least 10 years for a future conviction. The trial court found that the limiting phrase “involving a minor” applied only to the last category on the list. Thus, the trial court held that Lockhart’s prior sexual assault conviction fell within the purview of 18 U. S. C. § 2252(b)(2) and sentenced Lockhart to ten years in prison for his child pornography conviction. Lockhart challenged the court’s interpretation of that statute. The issue was whether the phrase “involving a minor” modified all items in the list of predicate crimes, or only the item that immediately preceded the phrase. Lockhart argued that the limiting phrase should be applied to each crime in the list. Thus, Lockhart argued, because his previous conviction did not involve a minor, he should not be subjected to the mandatory minimum sentence. The appeals court agreed with the trial court, holding that the phrase “involving a minor” modified only “abusive sexual conduct.” The Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

Dissent (Kagan, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 366,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,300 briefs, keyed to 223 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.