United States v. Nikequis Lachristopher Green, 24-11526

Defendant Nikequis LaChristopher Green pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) after a traffic stop revealed a rifle in his vehicle.
Green had three prior Alabama convictions: two second‑degree domestic‑violence convictions (violent felonies) and a conviction for possession of marijuana with intent to distribute (an Alabama offense punishable up to 10 years).
The district court applied the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), finding three qualifying predicates and imposing the 15‑year mandatory minimum.
Green challenged the ACCA enhancement under the Fifth Amendment’s equal‑protection component of due process, arguing it is irrational to treat his Alabama drug conviction as a “serious drug offense” when the federal analogue for similar marijuana possession carries a lower maximum sentence.
The district court rejected the challenge; the Eleventh Circuit reviewed the constitutional question de novo.
The Eleventh Circuit affirmed, holding Congress had a rational basis to treat state convictions as ACCA predicates and to defer to state sentencing judgments when identifying “serious” prior offenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether applying ACCA § 924(e) to Green violates the Fifth Amendment’s equal‑protection component as applied	Green: Applying ACCA is irrational because his Alabama drug conviction qualifies as a "serious drug offense" (10‑year state max) while the federal analogue would not (federal max <10 years), so he is punished more harshly solely because a state, not the federal government, prosecuted him	Government: Congress rationally may rely on state‑law classifications and sentences to identify serious prior offenses for ACCA; Congress targets recidivists and can defer to state judgments about local seriousness	Held: Affirmed — rational‑basis review satisfied; Congress may treat state convictions differently and rely on state sentencing judgments for ACCA predicates

Brown v. United States, 602 U.S. 101 (2024) (ACCA’s purpose is to single out repeat offenders who commit serious offenses and pose grave risk when possessing firearms)
Wooden v. United States, 595 U.S. 360 (2022) (repeat offenders justify higher punishment under ACCA)
Taylor v. United States, 495 U.S. 575 (1990) (ACCA targets offenses of a certain level of seriousness involving violence or risk thereof)
Rodriguez v. United States, 553 U.S. 377 (2008) (Congress may reasonably defer to state lawmakers’ judgments about the seriousness of state offenses)
Barbier v. Connolly, 113 U.S. 27 (1884) (equal punishment principle in criminal justice)
FCC v. Beach Communications, 508 U.S. 307 (1993) (standard for rational‑basis review of legislative classifications)
Romer v. Evans, 517 U.S. 620 (1996) (rational‑basis review explanation)
United States v. Deshazior, 882 F.3d 1352 (11th Cir. 2018) (sentence constitutionality reviewed de novo)
United States v. White, 837 F.3d 1225 (11th Cir. 2016) (interpreting state drug offense as ACCA predicate)
United States v. Titley, 770 F.3d 1357 (10th Cir. 2014) (rejecting similar challenge that ACCA’s reliance on state convictions is irrational)