United States v. Smith, No. 15-3311 (6th Cir. 2016)
Annotate this CaseSmith pled guilty to two counts of possessing firearms as a felon under 18 U.S.C. 922(g)(1), and to other federal crimes and was sentenced to 200 months in prison. Smith challenged the enhancement of his sentence under the enumerated-offenses clause of the Armed Career Criminal Act (ACCA), under which a person who violates 18 U.S.C. 922(g) and has three previous convictions for a violent felony shall be imprisoned for a minimum of 15 years, 18 U.S.C. 924(e)(1). Under the ACCA’s enumerated-offenses clause, a “violent felony” includes a crime “punishable by imprisonment for a term exceeding one year” and “is burglary, arson, or extortion, [or] involves [the] use of explosives.” Smith argued cited the Supreme Court’s 2015 decision, Johnson v. United States, invalidating a different ACCA clause, the residual clause, as unconstitutionally vague. That clause includes as a “violent felony” a crime that “otherwise involves conduct that presents a serious potential risk of physical injury to another.” The Sixth Circuit rejected his argument. Limiting language in the Johnson opinion makes clear that its holding does not extend to the enumerated-offenses clause. The enumerated-offenses clause gives ordinary people fair notice of the conduct it punishes and does not invite arbitrary enforcement.
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