Chambers v. United States
Encyclopedia
Chambers v. United States, No. 06-11206
(2008), was a recent case in which the Supreme Court of the United States
held that failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act
.
, enacted in 1984 and since amended, provides for enhanced sentences for felons who commit crimes with firearms. A felon convicted of a "violent felony" or a "serious drug offense" at least three times faces a minimum sentence of fifteen years in prison.
The petitioner, Deondery Chambers, pled guilty in District Court to the charge of being a felon in unlawful possession of a firearm. The prosecution sought to invoke the ACCA's mandatory 15-year prison term on the grounds that Chambers had three prior convictions which qualified: robbery and aggravated battery (1998), a drug conviction (1999), a failure to report for incarceration charge stemming from the robbery and battery conviction. The court had required Chambers to report to a local prison for 11 weekends of incarceration; Chambers missed four of the weekends and was convicted under Illinois law for "fail[ing] to report to a penal institution."
Chambers challenged the failure to report, arguing that it was not a "violent felony." The District Court disagreed, treating the failure to report as similar to an escape and therefore a violent felony under the ACCA. The United States Court of Appeals for the Seventh Circuit
upheld the District Court. Other Courts of Appeal had come to differing conclusions: the First Circuit agreed that failure to report qualified as a violent felony in United States v. Winn (2001), while the Ninth Circuit held that it did not in United States v. Piccolo (2006). The Supreme Court granted certiorari to resolve the split.
argued for the respondent. Roberts argued that "failure-to-report escape is similar in kind to burglary because it's purposeful, violent, and aggressive in the same way as burglary." Roberts argued that failure to report is an invitation for a violent confrontation between the police and the felon.
The Supreme Court held unanimously that a failure to report did not qualify as a violent felony for the purposes of the Armed Career Criminal Act. Justice Breyer
wrote the majority opinion which six other justices joined, while Justice Alito
wrote a concurrence which Justice Thomas
joined.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2008), was a recent case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that failing to report for incarceration does not qualify as a "violent felony" for the purposes of the Armed Career Criminal Act
Armed Career Criminal Act
The Armed Career Criminal Act of 1984 is a United States federal law that provides sentence enhancements for felons who commit crimes with firearms, if convicted of certain crimes three or more times....
.
Background
The Armed Career Criminal ActArmed Career Criminal Act
The Armed Career Criminal Act of 1984 is a United States federal law that provides sentence enhancements for felons who commit crimes with firearms, if convicted of certain crimes three or more times....
, enacted in 1984 and since amended, provides for enhanced sentences for felons who commit crimes with firearms. A felon convicted of a "violent felony" or a "serious drug offense" at least three times faces a minimum sentence of fifteen years in prison.
The petitioner, Deondery Chambers, pled guilty in District Court to the charge of being a felon in unlawful possession of a firearm. The prosecution sought to invoke the ACCA's mandatory 15-year prison term on the grounds that Chambers had three prior convictions which qualified: robbery and aggravated battery (1998), a drug conviction (1999), a failure to report for incarceration charge stemming from the robbery and battery conviction. The court had required Chambers to report to a local prison for 11 weekends of incarceration; Chambers missed four of the weekends and was convicted under Illinois law for "fail[ing] to report to a penal institution."
Chambers challenged the failure to report, arguing that it was not a "violent felony." The District Court disagreed, treating the failure to report as similar to an escape and therefore a violent felony under the ACCA. The United States Court of Appeals for the Seventh Circuit
United States Court of Appeals for the Seventh Circuit
The United States Court of Appeals for the Seventh Circuit is a federal court with appellate jurisdiction over the courts in the following districts:* Central District of Illinois* Northern District of Illinois...
upheld the District Court. Other Courts of Appeal had come to differing conclusions: the First Circuit agreed that failure to report qualified as a violent felony in United States v. Winn (2001), while the Ninth Circuit held that it did not in United States v. Piccolo (2006). The Supreme Court granted certiorari to resolve the split.
Opinion of the Court
Robert Hochman argued the case for the petitioner. Assistant to the Solicitor General Matthew D. RobertsMatthew D. Roberts
Matthew D. Roberts is an American lawyer who is an Assistant to the Solicitor General of the United States.-Schooling:He graduated from Harvard College magna cum laude in 1984 and graduated first in his class from Harvard Law School in 1989.-Career:...
argued for the respondent. Roberts argued that "failure-to-report escape is similar in kind to burglary because it's purposeful, violent, and aggressive in the same way as burglary." Roberts argued that failure to report is an invitation for a violent confrontation between the police and the felon.
The Supreme Court held unanimously that a failure to report did not qualify as a violent felony for the purposes of the Armed Career Criminal Act. Justice Breyer
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
wrote the majority opinion which six other justices joined, while Justice Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
wrote a concurrence which Justice Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
joined.