Justin Rashaad Brown v. United States
In brief
Courts applying ACCA must look to whether the drug was federally controlled when the earlier state drug offense occurred.
- Where it stands
- Decided
Decided 6-3 · May 23, 2024 · Opinion by Justice Alito
- What it’s about
- The Supreme Court ruled that a state drug conviction qualifies as a "serious drug offense" under the Armed Career Criminal Act (ACCA) if the drug was federally controlled at the time of the state conviction, even if it was later removed from federal schedules.
- Who it affects
- The decision can subject some people convicted of federal firearm offenses to ACCA's 15-year mandatory minimum based on older state drug convictions.
Summary: written with AI from the case record.
What it's about
The Court determined that ACCA requires a backward-looking approach to assess a defendant's prior criminal history based on the law in effect when the previous crimes were committed.
The case resolved when courts must compare state drug crimes with federal drug schedules when applying ACCA's enhanced sentence for people with three qualifying prior convictions.
Question presented
Does the "serious drug offense" definition in the Armed Career Criminal Act incorporate the federal drug schedules that were in effect at the time of the federal firearm offense?
What the Court decided
Holding
A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense. Pp. 4– 19. (a) The parties propose three different answers to the question whether the federal and state definitions of a drug must match when the state crime is committed or at some later point in time. The Government argues that a prior state drug conviction qualifies if the federal and state definitions of the relevant drug matched when the defendant committed the state crime. Jackson argues instead that the definitions must match when the defendant violates the federal felonin-possession statute. No. 22–6389, 47 F. 4th 147, and No. 22–6640, 55 F. 4th 846, affirmed.
- Result
- Affirmed
The vote
From the opinions
“A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.”
“But the relevant text does definitively answer the question presented here. And it establishes that courts should apply the drug schedules in effect at the time of the federal firearms offense that triggers ACCA’s potential application.”
What's next
Lower courts must apply the time-of-the-state-offense rule in ACCA sentencing cases. Federal prosecutors and defendants will assess prior state drug convictions using the federal schedules then in effect.
Why it matters
For example, a prior conviction may count even when the drug is no longer federally controlled at the time of the firearm offense.
Documents
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
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Opinion added: opinion
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Court Order added: Lower Court Orders/Opinions
Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Brown v. United States?
- A prior state drug conviction counts under ACCA if the drug was federally controlled when that state offense occurred, even if later removed from federal schedules.
- Who won Brown v. United States?
- The United States won. The Court affirmed the lower-court judgments by a 6-3 vote.
- What does Brown v. United States mean for firearm defendants?
- Some federal firearm defendants may face ACCA's 15-year mandatory minimum based on prior state drug convictions involving drugs later removed from federal schedules.
- Is the time-of-the-state-offense rule still the law after Brown v. United States?
- Yes. Courts must determine whether the drug was federally controlled when the earlier state drug offense occurred.
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.