Chambers v. United States

The Armed Career Criminal Act, enacted in 1984 and since amended, provides for enhanced sentences for felons who commit crimes with firearms. A felon convicted of a "violent felony" or a "serious drug offense" at least three times faces a minimum sentence of fifteen years in prison.

The petitioner, Deondery Chambers, pleaded guilty in District Court to the charge of being a felon in unlawful possession of a firearm. The prosecution sought to invoke the ACCA's mandatory 15-year prison term on the grounds that Chambers had three prior convictions which qualified: robbery and aggravated battery (1998), a drug conviction (1999), a failure to report for incarceration charge stemming from the robbery and battery conviction. The court had required Chambers to report to a local prison for 11 weekends of incarceration; Chambers missed four of the weekends and was convicted under Illinois law for "fail[ing] to report to a penal institution."[3]

Chambers challenged the failure to report, arguing that it was not a "violent felony." The District Court disagreed, treating the failure to report as similar to an escape and therefore a violent felony under the ACCA. The United States Court of Appeals for the Seventh Circuit upheld the District Court.[4] Other Courts of Appeal had come to differing conclusions: the First Circuit agreed that failure to report qualified as a violent felony in United States v. Winn (2001),[5] while the Ninth Circuit held that it did not in United States v. Piccolo (2006).[6] The Supreme Court granted certiorari to resolve the split.

Robert Hochman argued the case for the petitioner. Assistant to the Solicitor General Matthew D. Roberts argued for the respondent.[7] Roberts argued that "failure-to-report escape is similar in kind to burglary because it's purposeful, violent, and aggressive in the same way as burglary." Roberts argued that failure to report is an invitation for a violent confrontation between the police and the felon.[8]

The Supreme Court held unanimously that a failure to report did not qualify as a violent felony for the purposes of the Armed Career Criminal Act. Justice Breyer wrote the majority opinion which six other justices joined, while Justice Alito wrote a concurrence which Justice Thomas joined.

• Text of Chambers v. United States, 555 U.S. 122 (2009) is available from: Cornell  CourtListener  Google Scholar  Justia  Oyez (oral argument audio)  Supreme Court (slip opinion) (archived)