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Fleming v. United States

Updated Sep 20, 2026

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.

Illustration for Fleming v. United States
Conceptual illustration · AI-generated

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

2

Docket activity

25
  • New analysis added

    Sep 20, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 20, 2026 · Generated

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    Sep 20, 2026 · Court records

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    Sep 20, 2026 · Court records

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    Sep 20, 2026 · Court records

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    Sep 19, 2026 · Court records

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    Sep 19, 2026 · Court records

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    Sep 19, 2026 · Court records

Older entries are on the full docket.

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.

Checked Sep 20, 2026Methodology

Court records and filings

Reporting and analysis