Lockhart v. United States
United States Supreme Court
577 U.S. 347 (2016)
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
Holding and Reasoning (Sotomayor, J.)
Dissent (Kagan, J.)
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