Brown v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Brown v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Brown v. United States.
The Supreme Court addressed whether state drug convictions qualify as 'serious drug offenses' under the Armed Career Criminal Act (ACCA) if the drug was on federal schedules at the time of the offense but later removed. The Court affirmed that such convictions remain ACCA predicates if the federal and state definitions matched when the state crime was committed. This decision impacts sentencing enhancements for firearm possession by convicted felons.
Holding
The single most important “bottom line” of what the Court decided in Brown v. United States.
The Court held that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.
Constitutional Concepts
These are the Constitution-related themes that appear in Brown v. United States. Click a concept to see other cases that involve the same idea.
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Why Ex Post Facto is relevant to Brown v. United States
The case involves whether changes in federal drug schedules can retroactively affect the classification of a state conviction as a 'serious drug offense' under ACCA.
Syllabus excerpt (verbatim)The question presented is whether a state crime constitutes a 'serious drug offense' if it involved a drug that was on the federal schedules when the defendant possessed or trafficked in it but was later removed.
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Why Preemption is relevant to Brown v. United States
The case discusses the relationship between federal and state drug definitions and how federal law impacts state convictions under ACCA.
Syllabus excerpt (verbatim)A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.
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Why Procedural Due Process is relevant to Brown v. United States
The case touches on procedural fairness in sentencing, particularly how changes in law affect the determination of past offenses.
Syllabus excerpt (verbatim)Petitioners also argue that the Government's interpretation would unduly burden courts and defendants by requiring them to undertake the laborious task of digging up old federal drug schedules.
Key Quotes
Short excerpts from the syllabus in Brown v. United States that support the summary and concepts above.
A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.
The Government's interpretation also best fulfills ACCA's statutory objectives.
Petitioners' interpretations, by contrast, would treat those federal and state offenses differently.