Johnson v. United States, 135 S. Ct. 2551

Samuel Johnson, a felon with prior convictions including robbery and illegal possession of a sawed-off shotgun, pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g).
The government sought an enhanced sentence under the Armed Career Criminal Act (ACCA), which imposes a 15‑year minimum when a defendant has three prior convictions for a "violent felony." 18 U.S.C. § 924(e)(1)–(2).
ACCA defines "violent felony" by (i) an element requiring physical force, (ii) four enumerated offenses (burglary, arson, extortion, explosives), and (iii) a residual clause covering offenses that "otherwise involve conduct that presents a serious potential risk of physical injury to another." § 924(e)(2)(B).
The district court and the Eighth Circuit treated Johnson’s prior Minnesota conviction for unlawful possession of a short‑barreled (sawed‑off) shotgun as a violent felony under ACCA’s residual clause and imposed the 15‑year minimum.
The Supreme Court granted certiorari to decide whether Minnesota’s offense qualifies under the residual clause and—after supplemental briefing and reargument—addressed whether the residual clause is unconstitutionally vague under the Due Process Clause.
The Court concluded the residual clause is void for vagueness, overruled its prior contrary statements in James and Sykes, reversed the Eighth Circuit, and remanded for further proceedings consistent with that holding.

Issue	Petitioner (Johnson) Argument	Government / Respondent Argument	Held
Whether ACCA’s residual clause ("conduct that presents a serious potential risk of physical injury") is unconstitutionally vague	The clause is indeterminate because it requires judges to imagine an "ordinary case" and to measure vague "serious potential risk," producing unpredictable results and arbitrary enforcement	The clause supplies an ascertainable standard; prior precedent and many statutes use comparable risk standards; some offenses clearly fall within the clause	The residual clause is unconstitutionally vague (Due Process) and cannot be used to impose ACCA enhancements; James and Sykes are overruled as to this point
Whether unlawful possession of a short‑barreled shotgun (Minn.) is a "violent felony" under the residual clause	Johnson argued the conviction should not qualify (and more broadly challenged the clause’s vagueness)	Government argued sawed‑off shotguns are particularly dangerous and commonly used in violent crime so the ordinary case presents serious risk	Because the Court held the residual clause void, it did not rest its decision solely on statutory interpretation; Justices Kennedy and Thomas concurred in the judgment—Kennedy agreed the conviction does not qualify under the categorical approach; Thomas would decide that the offense does not qualify on statutory‑interpretation grounds

James v. United States, 550 U.S. 192 (2007) (held attempted burglary qualified under ACCA residual clause; earlier discussion rejecting vagueness claim in a footnote)
Begay v. United States, 553 U.S. 137 (2008) (held DUI not a violent felony; introduced the "in kind as well as in degree" analysis)
Chambers v. United States, 555 U.S. 122 (2009) (held failure to report to prison not a violent felony; relied on statistical evidence about risk)
Sykes v. United States, 564 U.S. 1 (2011) (held vehicular flight qualified under residual clause; rejected some aspects of Begay)
Taylor v. United States, 495 U.S. 575 (1990) (adopted the categorical approach for ACCA determinations)
L. Cohen Grocery Co. v. United States, 255 U.S. 81 (1921) (early vagueness precedent striking statute for lack of ascertainable standard)
Connally v. General Constr. Co., 269 U.S. 385 (1926) (vagueness doctrine as a due‑process requirement that statutes provide fair notice)
Kolender v. Lawson, 461 U.S. 352 (1983) (due‑process vagueness principles: prohibiting laws that fail to give ordinary people fair notice or invite arbitrary enforcement)