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Docket 24-5774October Term 2025 (2025–2026)

Dwayne Barrett, Petitioner v. United States

A single firearm act that falls under both of these federal statutes supports one conviction, not two.

Case status

Current stage
Decided
Latest event
Decision released Jan 14, 2026
Case AcceptedMar 3, 2025
Arguments HeardOct 7, 2025
Decision ReleasedJan 14, 2026
What it's about

The Supreme Court unanimously held that Congress did not authorize convictions under both 18 U.S.C. §§924(c)(1)(A)(i) and (j) for a single act that violates both provisions. A person who uses a firearm in a crime of violence that results in death faces one conviction, not two. Justice Jackson wrote for the 9-0 Court.

Question presented

May a defendant who commits a single act that violates two statutory provisions be convicted under both provisions?

Case path

United States Court of Appeals for the Second Circuit / Decision released Jan 14, 2026

Area

Criminal Procedure, Gun Rights

Briefing

What it's about

The Court decided whether one act with a gun during a violent crime that causes death can produce two federal convictions under 18 U.S.C. §§924(c)(1)(A)(i) and (j). The justices said no: Congress allowed only one conviction for that single act, not two.

Vote

The Court ruled 9-0 for Barrett, and Justice Jackson wrote the opinion.

Congress did not authorize convictions under both 18 U.S.C. §§924(c)(1)(A)(i) and (j) for a single act that violates both provisions.

— Justice Justice Jackson(majority)

Impact

This limits how prosecutors and courts can stack convictions when the same gun use violates both provisions at once. For example, a defendant in a firearm-death case covered by both sections can receive one conviction instead of two for the same act.

What's next

Lower courts must apply this rule in pending and future cases involving these two statutes. Prosecutors, defense lawyers, and judges will need to adjust charges, convictions, or sentencing where one act had been treated as two convictions.

What was the main fight in Barrett v. United States?

The case asked whether one act could trigger two convictions under §§924(c)(1)(A)(i) and (j). The Court said Congress allowed only one conviction.

Who is most affected by the Supreme Court's decision in Barrett?

Federal defendants, prosecutors, and trial judges in firearm cases are most affected. Cases involving one gun act that also caused death cannot produce both convictions.

What happens next after the Barrett decision?

Lower courts must follow the ruling in current and future cases. Lawyers and judges may need to revisit charges, convictions, or sentencing built on both provisions.

Decision

Decision record

What the Court decided

A single firearm act that falls under both of these federal statutes supports one conviction, not two.

Impact

This affects federal defendants, prosecutors, and judges in cases involving one firearm-related act under both §924(c)(1)(A)(i) and §924(j). If one robbery-related firearm act causes death, the defendant can face one conviction (formal finding of guilt), not two. That changes charging and sentencing in those cases. Next, lower courts must apply the Supreme Court’s rule instead of

Not official Court text.