The Johnson's Case

The United States Constitution’s Fifth Amendment requires that all people are given equal due process rights and a violation of those rights violate the constitution. The defendant, Johnson, argued that his convictions “should not be considered violent felonies and the Armed Career Criminal Act was unconstitutionally vague (Supreme court).” In 2010, the FBI started to investigate Samuel Johnson because of his involvement in the National Social Movement. After he left that movement he joined the Aryan Liberation Movement. While Johnson was a member, he disclosed incriminating information to an undercover FBI agent. Johnson told the agent that he manufactured weapons and explosives for the Aryan Liberation Movement and possessed several other weapons. The Bureau also suspected that Johnson had planned to engage in terrorism against the Mexican consulate and liberal bookstores (Supreme court).

In 2012, Johnson was arrested and admitted to possessing some of the weapons. Convicted felons are prohibited from buying and having weapons since Johnson did both, the Government sought to sentence Johnson harsher. Johnson pleads guilty and “the Government sought an enhanced sentence under the Armed Career Criminal Act (ACAA), which imposes an increased prison term upon a defendant with three prior convictions for a “violent felony,” (Supreme court).” Johnson previously committed two felonies, attempted simple robbery and simple robbery. The Government argued that Johnson’s former conviction of unlawful possession of a short-barreled shotgun could be defined as a violent felony. The District Court agreed and sentenced Johnson to a 15-year mandatory minimum under the Armed Career Criminal Act. Johnson fought to appeal his sentence. Johnson filed an appeal to the Eighth Circuit Court of Appeals. This court had previously stood behind the residual clause in (James v. the United States, 550 U. S. 192) and found that the clause was void for vagueness (Supreme court). The Eighth Circuit Court of Appeals affirmed the District courts ruling. The Eighth Circuit Court of Appeals found that unlawful possession of a short-barreled shotgun is categorized as a violent felony under the residual clause. The residual clause requires the application of “serious potential risk” needed to be applied to an ordinary case of the crime (Supreme court).

The Government presented the idea that possession of a short-barreled shotgun could qualify as a violent felony because of the perceived risk as well as the purpose of the weapon. The residual clause has resulted in a divide among the lower federal courts because it is hard to apply it consistently (Supreme court). Johnson fought to prove that the residual provision’s definition of “violent felony” is unconstitutionally vague. Johnson filed another appeal after receiving the Eighth Circuit Court of appeals ruling and appealed to the U.S Supreme Court. The opinion of the court referenced the features pertaining to the residual clause. The residual clause leaves severe uncertainty about how to estimate the risk of a crime, which makes it unconstitutionally vague. The residual clause also fails to include real-life facts or “statutory features of a case (Supreme court).” The residual clause “requires a judge to imagine how the idealized ordinary case of the crime subsequently plays out (Supreme court).” The Supreme Court had to analyze all of the factors dealing with the vagueness of the Armed Career Criminal Act before giving a decision to Johnson.

The court had to question if Johnson’s constitutional rights were violated or not when he was given a mandatory minimum sentence of 15 years when the Armed Career Criminal Act’s definition of “violent felonies” was vague. Justice Scalia delivered the opinion of the 8-1 majority. Justice Scalia, Justice Roberts, Justice Ginsburg, Justice Breyer, Justice Sotomayor, and Justice Kagan agreed that Johnson’s appeal should be upheld. They believed that the residual clause of the Armed Career Criminal Act gave no guidelines for how the court could assess Johnson’s behavior. They also believed that the definition of “violent felony” was too vague, and allowed for different interpretation which violated the Due Process Clause (Supreme court). Justice Kennedy and Justice Thomas concurred. Justice Kennedy concurred because he believed that the residual clause of the Armed Career Criminal Act is not unconstitutionally vague, but also believed that the short-barreled shotgun does not qualify as a violent felony. Justice Thomas also concurred because he did not think that a short-barreled shotgun constituted as a “violent felony” under the residual clause of the Armed Career Criminal Act. He also believed that Johnson’s sentence should not stand, under ordinary principles of statutory interpretation, not under the violation of the Due Process Clause (Supreme court).

Justice Alito dissented because he believed the residual clause of the Armed Career Criminal Act is not unconstitutionally vague (Supreme court). He believed that Johnson’s behavior was a career criminal and according to his criminal history and behavior, his offense qualified to be a “violent felony.” Justice Alito believed Johnson was a violent felon from the moment he was caught with dangerous weapons. Justice Alito believed that the residual clause of the Armed Career Criminal Act does not violate the Due Process Clause. The court upheld Johnson’s appeal that “violent felony” definition in the Armed Career Criminal Act is vague. Justice Scalia delivered the opinion of the court and the majority opinion found that imposing an increased sentence under the Armed Career Criminal Act’s unconstitutionally vague residual clause violates the due process rights of the Fifth Amendment. The Supreme Court reversed the Eighth Circuit Court of Appeals decision and remanded the case in 2015 (SupremeCourt).