Erlinger v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Erlinger 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 Erlinger v. United States.
In Erlinger v. United States, the Supreme Court addressed whether a jury must determine if past offenses were committed on separate occasions for the purpose of sentence enhancement under the Armed Career Criminal Act (ACCA). The Court vacated the lower court's decision, emphasizing the need for a jury to make this determination beyond a reasonable doubt. The decision aligns with the Fifth and Sixth Amendments' requirements for jury involvement in factual determinations affecting sentencing.
Holding
The single most important “bottom line” of what the Court decided in Erlinger v. United States.
The Court held that the Fifth and Sixth Amendments require a unanimous jury to determine beyond a reasonable doubt whether a defendant's past offenses were committed on separate occasions for ACCA purposes.
Constitutional Concepts
These are the Constitution-related themes that appear in Erlinger v. United States. Click a concept to see other cases that involve the same idea.
-
Why Right to Jury Trial is relevant to Erlinger v. United States
The Court held that the determination of whether past offenses were committed on separate occasions must be made by a jury.
Syllabus excerpt (verbatim)The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant's past offenses were committed on separate occasions for ACCA purposes.
-
Why Procedural Due Process is relevant to Erlinger v. United States
The Court emphasized the requirement of due process in having a jury determine facts that affect sentencing.
Syllabus excerpt (verbatim)The Fifth Amendment further promises that the government may not deprive individuals of their liberty without 'due process of law.'
-
Why Double Jeopardy is relevant to Erlinger v. United States
The syllabus references the Double Jeopardy Clause in discussing protections at different stages of proceedings.
Syllabus excerpt (verbatim)The Fifth and Sixth Amendments' jury trial rights provide a defendant with entirely complementary protections at a different stage of the proceedings.
Key Quotes
Short excerpts from the syllabus in Erlinger v. United States that support the summary and concepts above.
The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt.
The government had to prove, among other things, that his three predicate convictions were 'committed on occasions different from one another.'
The Court decides no more than that.