United States v. Edward Young
766 F.3d 621
6th Cir.2014Background
- Young, a prior felon, helped a neighbor sort her late husband’s possessions and found seven shotgun shells in a box.
- He stored the shells to keep them away from his four children, unaware his felonies extended to ammunition under 18 U.S.C. § 922(g)(1).
- A consent search during a police investigation into burglaries uncovered the shells and other items; Young admitted possession.
- He was charged with being a felon in possession of ammunition, punishable by a fifteen-year mandatory minimum under ACCA § 924(e)(1) due to multiple prior felonies.
- The district court imposed the fifteen-year sentence; Young challenged the sentence as unconstitutional under the Eighth and Fifth Amendments; the court reviews de novo and affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ACCA as applied to Young violates the Eighth Amendment | Young argues the sentence is grossly disproportionate to a low-gravity offense. | The government contends deference to Congress; the sentence fits ACCA’s aims given recidivism. | Not grossly disproportionate; recidivism justified the severity. |
| Whether Young’s lack of notice renders the ACCA notice unconstitutional under the Fifth Amendment | Young contends he lacked notice that ammunition possession by felons was illegal. | Statute plainly prohibits possession of ammunition by felons; notice can be imputable despite ignorance. | Fifth Amendment notice requirement satisfied; no violation. |
Key Cases Cited
- Weems v. United States, 217 U.S. 349 ((1910)) (proportionality and duration principles for punishment)
- Solem v. Helm, 463 U.S. 277 ((1983)) (reaffirmed gross disproportionality limits and recidivism considerations)
- Graham v. Florida, 560 U.S. 48 ((2010)) (narrow proportionality principle for non-capital sentences)
- Ewing v. California, 538 U.S. 11 ((2003)) (recidivism informs gravity of offense under mandatory minimums)