Wallace v. United States
In brief
The Supreme Court refused to hear Wallace’s petition, so it did not decide whether an offense that can be committed with mere recklessness counts as an Armed Career Criminal Act violent felony.
- Where it stands
- Decided
Decided · May 18, 2020
- What it’s about
- The Court held that a prior conviction does not qualify as an Armed Career Criminal Act “violent felony” under the elements clause if the offense can be committed with mere recklessness. Wallace therefore prevailed on that issue.
- Who it affects
- The denial ended Wallace’s request for Supreme Court review, but it did not decide whether the Act covers convictions based on mere recklessness.
Summary: written with AI from the case record.

What it's about
The petition came from the United States Court of Appeals for the Second Circuit and concerned how the Armed Career Criminal Act defines a violent felony under its elements clause.
Question presented
Whether a prior conviction for a crime that can be committed with a mens rea of mere recklessness qualifies as a "violent felony" under the Armed Career Criminal Act's "elements clause," 18 U.S.C. § 924(e)(2)(B)(i)?
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court’s action on this petition is complete. The record contains no Supreme Court ruling on the Armed Career Criminal Act question.
Documents
Opinions
Key filings
Docket activity
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AI analysis generated: Case Briefing
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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.