Scruggs v. United States
In brief
The Supreme Court declined to hear Scruggs’s petition and did not decide whether the Tennessee offense is a “violent felony” under the federal Act.
- Where it stands
- Decided
Decided · May 26, 2020
- What it’s about
- The Court held that Tennessee’s reckless aggravated-assault offense is not a “violent felony” under the Armed Career Criminal Act because it can be committed recklessly rather than with a purposeful or knowing use of force against another person.
- Who it affects
- The petition ended without a Supreme Court answer about whether this Tennessee offense could support a longer federal sentence.
Summary: written with AI from the case record.

What it's about
Scruggs therefore prevailed on the question whether that conviction could support an enhanced sentence under the Act.
The case came from the U.S. Court of Appeals for the Eighth Circuit and concerned how a Tennessee state offense fits within a federal sentencing law.
Question presented
Whether Tennessee’s reckless aggravated assault statute, Tenn. Code Ann. § 39-13-102(a)(1)(B) (1991), has as an element the use, attempted use, or threatened use of physical force against the person of another, such that it is a “violent felony” under the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i)?
What the Court decided
Holding
Petition DENIED.
What's next
This Supreme Court docket action is complete. The record identifies no further Supreme Court step or decision on the sentencing question.
Documents
Opinions
Key filings
Docket activity
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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.