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Keywords

defendantstatutedue processpiracy
due processprosecutorpiracy

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United States v. Davis, 588 U.S. 445, 139 S.Ct. 2319, 204 L.Ed.2d 757, 19 Cal. Daily Op. Serv. 5908, 2019 Daily Journal D.A.R. 5650, 27 Fla. L. Weekly Fed. S 1031

Facts

Maurice Davis and Andre Glover committed a series of gas station robberies in Texas and were charged with multiple counts of robbery and conspiracy under the Hobbs Act, as well as additional charges under 18 U.S.C. § 924(c) for brandishing a firearm during these crimes. A jury convicted them on most counts, leading to significant prison sentences. The defendants argued that the residual clause of § 924(c) was unconstitutionally vague, which the Fifth Circuit initially rejected but later reversed after the Supreme Court's decision in Sessions v. Dimaya.

After Maurice Davis and Andre Glover committed a string of gas station robberies in Texas, a federal prosecutor charged both men with multiple counts of robbery affecting interstate commerce in violation of the Hobbs Act, 18 U.S.C. § 1951(a), and one count of conspiracy to commit Hobbs Act robbery.

Issue

Is the residual clause of 18 U.S.C. § 924(c)(3)(B) unconstitutionally vague under the Due Process Clause?

Is the residual clause of 18 U.S.C. § 924(c)(3)(B) unconstitutionally vague under the Due Process Clause?

Rule

The vagueness doctrine requires that laws provide clear standards to avoid arbitrary enforcement, rooted in the principles of due process and separation of powers.

In our constitutional order, a vague law is no law at all.

Analysis

The Supreme Court applied the vagueness doctrine to § 924(c)(3)(B), determining that the language requiring a categorical approach to define a 'crime of violence' was unconstitutionally vague. The Court noted that the statute's reliance on a judge's estimation of risk posed by an 'ordinary case' of a crime created unpredictability and arbitrariness, similar to issues found in previous cases like Johnson v. United States and Sessions v. Dimaya.

The Court held in each case that the imposition of criminal punishments cannot be made to depend on a judge's estimation of the degree of risk posed by a crime's imagined 'ordinary case.'

Conclusion

The Supreme Court concluded that the residual clause of § 924(c)(3)(B) is unconstitutionally vague, affirming in part and vacating in part the Fifth Circuit's ruling.

Section 924(c)(3)(B) is unconstitutionally vague.

Who won?

Maurice Davis and Andre Glover prevailed in part as the Supreme Court found the residual clause unconstitutional, which affected their convictions related to conspiracy.

The Fifth Circuit reversed course and held § 924(c)(3)(B) unconstitutional.

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