Chambers v. United States (2008)
- Docket
- 06-11206
- Decided
- 2008-01-01
Summary
Question: Does a conviction for felonious escape under Illinois law, arising from the defendant's failure to report for imprisonment, qualify as a "crime of violence" for the purposes of the federal Armed Career Criminals Act? Conclusion: No. Justice Stephen G. Breyer writing for the majority and joined by Chief Justice John G. Roberts, Justice John Paul Stevens, Justice Antonin G. Scalia, Justice Anthony M. Kennedy, Justice David H. Souter, and Justice Ruther Bader Ginsburg held that the "failure to report" crime does not satisfy the Armed Career Criminals Act's (ACCA) "crime of violence" definition. The Court reasoned that the "failure to report" crime does not "involve conduct that presents a serious potential risk of physical injury to another" as it is a crime of inaction and therefore should not be categorized as a "crime of violence". Justice Samuel A. Alito Jr. wrote a separate concurring opinion and was joined by Justice Clarence Thomas. While agreeing with the Court's analysis, Justice Alito highlighted the difficulty the courts have had in applying the ACCA. He encouraged Congress to amend the ACCA and include a specific list of crimes that appropriately enhance a sentence.