Case Summary
**Case Summary: United States v. Descamps**
**Docket Number:** 7855167
**Court:** United States Supreme Court
**Decision Date:** January 2013
**Overview:**
The case of United States v. Descamps revolves around the federal sentencing guidelines and the categorization of prior offenses in relation to the Armed Career Criminal Act (ACCA). At the heart of the case was whether a conviction for a crime classified under state law could be considered a "violent felony" under federal law for the purposes of sentencing enhancement.
**Background:**
The petitioner, Descamps, had a prior felony conviction for burglary under Washington state law. When he was convicted of unlawful possession of a firearm, the government sought to enhance his sentence under the ACCA, which applies to defendants with three or more prior convictions for violent felonies.
**Legal Issue:**
The central legal question was whether Descamps's prior burglary conviction qualified as a violent felony under the ACCA. The Court needed to determine the applicability of the "modified categorical approach" to assess whether Descamps's prior convictions corresponded to the federal definition of a violent felony.
**Supreme Court Decision:**
The Supreme Court ruled in favor of Descamps, holding that the modified categorical approach cannot be used for "purely divisible statutes" that do not set different elements for different types of offenses. The Court emphasized that the statute under which Descamps was convicted did not allow for distinguishing between types of burglaries based on the statutory elements but rather provided a generic definition of the crime, which did not match the federal definition of a violent felony.
**Significance:**
This decision clarified the standards for determining whether prior state convictions can be treated as violent felonies under federal law, limiting the government's ability to apply sentence enhancements based solely on prior convictions that do not strictly align with federal definitions. The ruling underscored the importance of ensuring that the specific elements of state offenses must align with the federal definitions for the purposes of enhanced sentencing under the ACCA.
**Conclusion:**
United States v. Descamps highlighted critical issues surrounding the application of the ACCA and the evaluation of prior state convictions in federal sentencing, ultimately providing a narrower interpretation of what constitutes a violent felony under federal law.