SCOTUSblog: Johnson v. United States
ACCA) provides a mandatory 15-year sentence for those who have been convicted of three "violent felon[ies.]" Johnson pleaded guilty, but reserved the right to challenge the applicability of the ACCA based upon a review of his prior convictions. On appeal, Johnson alleged that a prior conviction for possession of a short-barreled shotgun did not constitute a "violent felony." The Eighth Circuit disagreed, finding that possession of a short-barreled shotgun presented a serious risk of physical injury to another because it is roughly similar to the listed offenses within the ACCA, both in kind as well as the degree of risk for harm posed. As a result, the conviction was considered a violent felony and Johnson's conviction as an armed career criminal was affirmed.
Issue: The question before the Court is whether mere possession of a short-barreled shotgun should be treated as a violent felony under the Armed Career Criminal Act.
Holding: In an 8-1 decision, the Supreme Court ruled that imposing an increased sentence under ACCA’s residual clause violates due process.