Shular v. United States
2020 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Shular v. United States, 589 U.S. ___ (2020), is an opinion of the United States Supreme Court in which the Court held that, under the Armed Career Criminal Act of 1984, the definition of “serious drug offense” only requires that the state offense involve the conduct specified in the statute.[1] Unlike other provisions of the ACCA, it does not require that state courts develop “generic” version of a crime, which describe the elements of the offense as they are commonly understood, and then compare the crime being charged to that generic version to determine whether the crime qualifies under the ACCA for purposes of penalty enhancement. The decision states that offenses defined under the ACCA are "unlikely names for generic offenses," and are therefore unambiguous. This renders the rule of lenity inapplicable.[2][3][4]
Shular v. United States | |
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Argued January 21, 2020 Decided February 26, 2020 | |
Full case name | Eddie Lee Shular v. United States |
Docket no. | 18-6662 |
Citations | 589 U.S. (more) 140 S. Ct. 779 |
Argument | Oral argument |
Case history | |
Prior | United States v. Shular, 736 F. App'x 876 (11th Cir. 2018); cert. granted, 139 S. Ct. 2773 (2019). |
Holding | |
The definition of "serious drug offense" in the Armed Career Criminal Act (18 U.S.C. § 924(e)(2)(A)(ii)) requires only that the state statute involve conduct specified in the federal statute; it does not require that the state offense match a generic offense crafted by a federal court. | |
Court membership | |
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Case opinions | |
Majority | Ginsburg, joined by unanimous |
Concurrence | Kavanaugh |
Laws applied | |
Armed Career Criminal Act of 1984 |