What counts as violent crime
Samuel James Johnson v. United States
In brief
The Supreme Court overturned the Eighth Circuit’s ruling and sent Johnson’s case back, ruling that ACCA’s residual clause could not support an increased sentence without violating due process.
- Where it stands
- Decided
Decided 8-1 · June 26, 2015 · Opinion by Justice Scalia
- What it’s about
- The Supreme Court ruled that the Armed Career Criminal Act’s residual clause was too vague to support an increased sentence for Samuel Johnson, violating due process.
- Who it affects
- The ruling means Johnson’s sentence could not be increased under ACCA’s residual clause; his case returned to the Eighth Circuit.
Summary: written with AI from the case record.
What it's about
It overturned the Eighth Circuit’s decision and sent the case back to the lower court (remanded).
ACCA’s residual clause classified an offense as a “violent felony” based on whether it posed a “serious potential risk of physical injury.”
Question presented
Is the definition of "violent felony" in the Armed Career Criminal Act unconstitutionally vague?
What the Court decided
Holding
Imposing an increased sentence under ACCA’s residual clause violates due process. 708, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court found the clause too vague to support an increased sentence without violating due process.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Concurring · 2agreed with the result, wrote separately
- Thomaswrote separately
- Kennedywrote separately
- Dissenting · 1disagreed with the result
- Alitowrote the dissent
From the opinions
“The Court is tired of the Armed Career Criminal Act of 1984 (ACCA) and in particular its residual clause.”
What's next
The Eighth Circuit will take up Johnson’s case again under the Supreme Court’s ruling.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Johnson
More questions
- Did the Court invalidate the entire ACCA?
- No. The ruling addressed increased sentences imposed under ACCA’s residual clause; it did not invalidate the whole Act.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.