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United States v. Davis

139 S. Ct. 2319 (2019)

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United States v. Davis

United States Supreme Court

139 S. Ct. 2319 (2019)

Facts

Maurice Davis and Andre Glover (defendants) were indicted in federal district court on multiple charges related to a series of Texas gas station robberies. The jury convicted Davis and Glover on all but a single count. Davis and Glover were additionally charged with violations of 18 U.S.C. § 924(c), a provision that imposed heightened penalties if a firearm was involved in the commission of a violent felony. An offense could qualify as a crime of violence under the residual clause § 924(c) if the commission of the offense posed a substantial risk of involving physical force used against a person or his property. A person found to violate § 924(c) received a mandatory sentence of at least five years (or more, depending on whether the person had previously been convicted of violating § 924(c) and the extent to which the weapon was used in the crime) to be served consecutively to the sentence for the underlying offense. The jury found that Davis and Glover had violated § 924(c), and they were sentenced by the district court to longer terms of imprisonment. Davis and Glover appealed, arguing that the residual clause of § 924(c) was unconstitutionally vague. The appeal was denied, and Davis and Glover appealed to the United States Supreme Court. The Supreme Court vacated the enhanced sentence and remanded the case for reconsideration because a recent Supreme Court decision had held that a different residual clause, which contained similar language to the residual clause in § 924(c), was unconstitutionally vague. On remand, the court of appeals found that the language of the residual clause of § 924(c) was also unconstitutionally vague and reversed the addition of the consecutive sentence. The government appealed. The government agreed that the residual clause was unconstitutionally vague as it was historically understood and requested that the Supreme Court apply an interpretation of § 924(c) that focused on the specific facts of the underlying crime.

Rule of Law

Issue

Holding and Reasoning (Gorsuch, J.)

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