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What is the significance of the DESCAMPS v.
UNITED STATES Supreme Court case?
The DESCAMPS v.
UNITED STATES case, decided in 2013, established a new approach to determining whether a prior conviction qualifies as a predicate offense for purposes of sentencing enhancement under the Armed Career Criminal Act (ACCA).
Prior to DESCAMPS, courts used the "categorical approach" to determine if a prior conviction qualified, looking only at the elements of the crime, not the specific facts of the case.
DESCAMPS changed this, allowing a "modified categorical approach" in some cases.
The DESCAMPS decision significantly impacted federal sentencing, as the ACCA can add decades to a prison sentence for certain repeat offenders.
The new approach provided more flexibility in examining the record of conviction.
The case centered on Michael Descamps, who was convicted of being a felon in possession of a firearm.
His prior conviction for burglary in California was found to be a valid predicate offense, triggering the ACCA's 15-year mandatory minimum sentence.
Importantly, the DESCAMPS ruling clarified that the modified categorical approach can only be used when the statute of conviction is "divisible" - containing multiple, alternative elements.
This was a departure from prior precedent.
The decision was unanimous, 9-0, signaling the Court's agreement on the need to refine the categorical approach to better fit the realities of state criminal codes.
DESCAMPS has been cited thousands of times in subsequent federal court decisions, indicating its lasting significance in sentencing law.
Legal experts note the case struck a balance between the need for a uniform, categorical approach and the practical reality that state criminal codes can vary widely in their specificity.
The ruling was praised for providing clearer guidance to lower courts on how to properly examine prior convictions for ACCA purposes, reducing sentencing disparities.
Some argue DESCAMPS opened the door for defendants to challenge prior convictions more easily, though the Court stressed it was not overturning the core categorical approach.
The case built on the Court's previous decisions in Taylor v.
United States and Shepard v.
United States, which had addressed similar issues around the categorical approach.
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