Two convictions for one act
Barrett v. United States
In brief
For one act covered by both firearm provisions, the federal government may obtain only one conviction.
- Where it stands
- Decided
Decided 9-0 · January 14, 2026 · Opinion by Justice Jackson
- 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.
- Who it affects
- The decision prevents duplicate convictions for the same firearm-related act under these two provisions. It affects defendants sentenced under both sections for one act, as well as prosecutors and courts handling similar cases.
Summary: written with AI from the case record.
What it's about
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.
The case concerns how courts determine whether Congress allowed separate criminal convictions for overlapping federal laws.
Question presented
May a defendant who commits a single act that violates two statutory provisions be convicted under both provisions?
What the Court decided
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 8joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Gorsuchwrote separately
From the opinions
“Congress did not authorize convictions under both provisions for a single act that violates both.”
What's next
Lower courts must apply the decision in future cases involving these two provisions. Parties with two convictions for a single act may seek review consistent with the Court's decision.
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
Show 7 moreShow fewer
New analysis added
New analysis added
Judgment Issued.
Adjudged to be REVERSED IN PART and case REMANDED. Jackson, J., delivered the opinion of the Court with respect to Parts I, II, III, IV-A, and IV-B, and an opinion with respect to Part IV-C, in which Roberts, C. J., and Sotomayor and Kagan, JJ., joined. Gorsuch, J., filed an opinion concurring in part.
Opinion added: opinion
Opinion added: Opinion of the Court - KJ
Audio Recording added: Oral Arguments - Barrett
More questions
- What did the Supreme Court rule in Barrett v. United States?
- The Court said one act cannot produce convictions under both 18 U.S.C. §§ 924(c)(1)(A)(i) and (j).
- Who is affected by the Barrett decision?
- Defendants charged under both provisions for one firearm-related act are affected. Federal prosecutors and lower courts must also follow the decision.
- What happens next after Barrett v. United States?
- Lower courts must use the Court's rule in similar cases. Affected parties may ask courts to review duplicate convictions.
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.