Shular v. United States
140 S. Ct. 779
| SCOTUS | 2020Background
- Petitioner Eddie Lee Shular pleaded guilty in federal court to being a felon in possession of a firearm and to federal drug charges; district court imposed ACCA's 15‑year mandatory minimum based on prior state drug convictions.
- Shular's prior Florida convictions (Fla. Stat. § 893.13(1)(a)) were for selling and possessing with intent to sell cocaine; Florida law treats lack of knowledge of illegality as an affirmative defense rather than an element.
- The Eleventh Circuit affirmed, applying circuit precedent that § 924(e)(2)(A)(ii) requires only that the state offense “involve” certain conduct, not that it match a labeled “generic” offense.
- Circuits were split on whether § 924(e)(2)(A)(ii) demands a generic‑offense matching exercise or instead asks whether the elements of the state offense necessarily entail the listed conduct.
- The Supreme Court granted certiorari to resolve that split and affirmed the Eleventh Circuit, holding the ACCA clause refers to conduct (manufacturing, distributing, possessing with intent) rather than named generic offenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 924(e)(2)(A)(ii) requires courts to define and compare a "generic" drug offense before applying ACCA | Shular: statute names generic offenses; court must identify generic elements (including mens rea) and compare state offense to them | United States: statute describes conduct; courts should ask whether state‑law elements necessarily entail the listed conduct (Kawashima approach) | Held: § 924(e)(2)(A)(ii) refers to conduct, not generic offense names; no generic‑offense matching required |
| Whether rule of lenity requires resolving ambiguities in favor of defendant | Shular: ambiguity about whether statute requires knowledge element merits lenity | United States: statutory text and context are clear that statute targets conduct; lenity inapplicable | Held: No grievous ambiguity after traditional interpretation; lenity does not apply |
Key Cases Cited
- Taylor v. United States, 495 U.S. 575 (1990) (endorsing the categorical approach and defining "generic" burglary for ACCA purposes)
- Mathis v. United States, 579 U.S. 500 (2016) (distinguishing when a generic‑offense comparison is required and explaining categorical approach limits)
- Kawashima v. Holder, 565 U.S. 478 (2012) (applying categorical approach by asking whether offense "involves" specified conduct rather than defining a generic crime)
- Stokeling v. United States, 586 U.S. _ (2019) (interpreting statute by reference to whether an offense "has as an element" specified conduct)
- Nijhawan v. Holder, 557 U.S. 29 (2009) (discussing "generic" crime usage versus case‑specific conduct)
- United States v. Shabani, 513 U.S. 10 (1994) (explaining rule of lenity applies only after traditional tools of construction leave grievous ambiguity)