Daniels v. United States
Encyclopedia
Daniels v. United States, 531 U.S. 374 (2001), was a decision by the Supreme Court of the United States
involving the Armed Career Criminal Act of 1984. The Court ruled, in a 5-4 decision, that a defendant sentenced under that act could not challenge, on appeal, previous convictions that were used to increase his new sentence.
. Under the Armed Career Criminal Act of 1984, which imposes a mandatory minimum 15-year sentence on anyone convicted of being a felon in possession of a firearm and who has three previous convictions for a violent felony, Daniels' sentence was enhanced. After an unsuccessful appeal, Daniels filed a motion to vacate, set aside, or correct his federal sentence. Daniels argued that his sentence violated the Constitution
because it was based in part on two prior convictions that were themselves unconstitutional. The District Court denied the motion. The Ninth Circuit Court of Appeals affirmed the decision, reasoning that they could only review those prior convictions if a Gideon
violation was alleged. Daniels sought review
in the Supreme Court, which agreed to hear the case.
, the Supreme Court affirmed the lower courts' dismissal of Daniels' claim. The Court stated that the nonexistent or unsuccessful pursuit of available challenges to the constitutionality of prior state convictions, which were used to enhance a federal sentence, precluded such challenge to collaterally attack a federal sentence. "[Daniels] could have pursued his claims while he was in custody on those convictions," wrote Justice O'Connor for the majority. "As his counsel conceded at oral argument, there is no indication that [Daniels] did so or that he was prevented from doing so by some external force." Three other Justices agreed with the decision in full while Justice Antonin Scalia
agreed with the understanding that Daniels, under different circumstances, could receive special review of prior convictions.
Dissents
Justice David H. Souter wrote a dissenting opinion, disagreeing with the majority's usage of the text of the Act in question. Justice Stephen Breyer
also filed a dissent, writing that the silence of a Congressional statute
to discuss the implications of an enhanced sentence would allow for challenges to that enhanced sentence.
External links* Oral Argument audio at the OYEZ Project http://www.law.cornell.edu/supct/html/99-9136.ZO.html
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...
involving the Armed Career Criminal Act of 1984. The Court ruled, in a 5-4 decision, that a defendant sentenced under that act could not challenge, on appeal, previous convictions that were used to increase his new sentence.
Background and lower court proceedings
In 1994, Earthy D. Daniels, Jr., was convicted of being a felon in possession of a firearmFirearm
A firearm is a weapon that launches one, or many, projectile at high velocity through confined burning of a propellant. This subsonic burning process is technically known as deflagration, as opposed to supersonic combustion known as a detonation. In older firearms, the propellant was typically...
. Under the Armed Career Criminal Act of 1984, which imposes a mandatory minimum 15-year sentence on anyone convicted of being a felon in possession of a firearm and who has three previous convictions for a violent felony, Daniels' sentence was enhanced. After an unsuccessful appeal, Daniels filed a motion to vacate, set aside, or correct his federal sentence. Daniels argued that his sentence violated the Constitution
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
because it was based in part on two prior convictions that were themselves unconstitutional. The District Court denied the motion. The Ninth Circuit Court of Appeals affirmed the decision, reasoning that they could only review those prior convictions if a Gideon
Gideon v. Wainwright
Gideon v. Wainwright, , is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required under the Sixth Amendment of the Constitution to provide counsel in criminal cases for defendants who are unable to afford their own...
violation was alleged. Daniels sought review
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
in the Supreme Court, which agreed to hear the case.
Majority opinion
In an opinion delivered by Justice Sandra Day O'ConnorSandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
, the Supreme Court affirmed the lower courts' dismissal of Daniels' claim. The Court stated that the nonexistent or unsuccessful pursuit of available challenges to the constitutionality of prior state convictions, which were used to enhance a federal sentence, precluded such challenge to collaterally attack a federal sentence. "[Daniels] could have pursued his claims while he was in custody on those convictions," wrote Justice O'Connor for the majority. "As his counsel conceded at oral argument, there is no indication that [Daniels] did so or that he was prevented from doing so by some external force." Three other Justices agreed with the decision in full while Justice Antonin Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
agreed with the understanding that Daniels, under different circumstances, could receive special review of prior convictions.
Dissents
Justice David H. Souter wrote a dissenting opinion, disagreeing with the majority's usage of the text of the Act in question. Justice Stephen 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....
also filed a dissent, writing that the silence of a Congressional statute
Statute
A statute is a formal written enactment of a legislative authority that governs a state, city, or county. Typically, statutes command or prohibit something, or declare policy. The word is often used to distinguish law made by legislative bodies from case law, decided by courts, and regulations...
to discuss the implications of an enhanced sentence would allow for challenges to that enhanced sentence.
External links* Oral Argument audio at the OYEZ Project http://www.law.cornell.edu/supct/html/99-9136.ZO.html