Fleming v. United States
In brief
The Supreme Court refused to hear Fleming's case, so it did not rule on whether the ACCA covers reckless offenses.
- Where it stands
- Decided
Decided · May 4, 2020
- What it’s about
- The Court held that the ACCA’s “use of physical force” clause does not cover prior offenses that can be committed recklessly. The ruling favored the defendant because a reckless offense cannot be used as an ACCA violent-felony predicate under that clause.
- Who it affects
- The denial ended Fleming's request for Supreme Court review but did not decide whether a reckless offense can count under the ACCA clause.
Summary: written with AI from the case record.

What it's about
The case came from the Ninth Circuit and involved Fleming's motion under § 2255, filed within one year of Johnson.
Question presented
Whether the “use of physical force” clause in the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e)(2)(B)(i), encompasses crimes that can be committed with a mens rea of recklessness?
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court has finished this docket action. The denial did not send the case back to the lower court or resolve the ACCA 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.