Descamps v. United States
Descamps v. United States, 570 U.S. 254 (2013), was a case in which the United States Supreme Court clarified standards for evaluating potential prior offenses under the Armed Career Criminal Act (ACCA). In an 8–1 decision written by Justice Elena Kagan, the Supreme Court held that judges may only look at the statutory elements of a crime, rather than the facts associated with that particular crime, "when the crime of which the defendant was convicted has a single, indivisible set of elements." In his review of the case for SCOTUSblog, Daniel Richman opined that following the Court's decision, "[w]hether or not a prior conviction is going to 'count' will have to be determined as mechanically as possible."
|Descamps v. United States|
|Argued January 7, 2013|
Decided June 20, 2013
|Full case name||Matthew Robert Descamps, Petitioner v. United States|
|Citations||570 U.S. 254 (more)|
|Opinion announcement||Opinion announcement|
|Under the Armed Career Criminal Act, judges may not look at facts associated with a crime (the "modified categorical approach") when criminal statutes contain a single, indivisible set of elements|
|Majority||Kagan, joined by Roberts, Scalia, Kennedy, Ginsburg, Breyer, Sotomayor|
|Concurrence||Thomas (in judgment only)|
|Armed Career Criminal Act|
- Descamps v. United States, 570 U.S. 254 (2013).
- Descamps, slip op. at 2.
- Daniel Richman, Opinion analysis: When is a burglary not a burglary?, SCOTUSblog (Jun. 20, 2013).
- Text of Descamps v. United States, 570 U.S. 254 (2013) is available from: CourtListener Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion)
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