United States v. Batchelder

442 U.S. 114 (1979)

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United States v. Batchelder

United States Supreme Court
442 U.S. 114 (1979)

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Facts

Batchelder (defendant) was convicted of violating 18 U.S.C. 922 (h), a provision of the Omnibus Crime Control and Safe Streets Act of 1968 (the Omnibus Act). Section 922(h) prohibits a convicted felon from receiving a firearm that has been in interstate commerce. Those convicted of violating 922(h) can be sentenced to any of the penalties listed in 924(a). A second provision of the Omnibus Act, 18 U.S.C. App. 1202(a), also prohibits a convicted felon from receiving a firearm that has been in interstate commerce. Although both provisions prohibit the same conduct, 1202(a) carries lighter penalties with the maximum being 2 years in prison. The district court sentenced Batchelder to five years in prison. This was the maximum penalty allowed under the provision he was convicted of violating. The appellate court upheld Batchelder’s conviction but not the five-year prison sentence he received. Since both provisions prohibited the same conduct, the court interpreted the Omnibus Act to allow only the two-year maximum penalty of the 1202 provision. The court noted that ambiguity in a criminal statute should be interpreted in the defendant’s favor, and that 924(a)’s penalties were repealed by the later addition of 1202(a). The Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

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