Logan v. United States: Decision

As expected, the US Supreme Court unanimously rejected Logan's reading of the Armed Career Criminal Act ("ACCA") and affirmed the 7th Circuit Court of Appeals by holding that the term "civil rights restored" In 18 USC 921(a)(20) must carry its ordinary meaning in order to be applicable to a defendant. You recall that Logan, convicted of three misdemeanors in WI, each of which made him eligible for three years imprisonment, and together made him eligible for the 15 year minimum sentence of the ACCA when he was subsequently convicted of being a felon in possession of a handgun, had argued that the "civil rights restored" provision of the law should apply to him. That is, he argued that he shouldn't be eligible for a 15 year sentence because he fit one of the "exceptions" of 921(a)(20). The fact that his civil rights were never taken away was no obstacle to his argument; indeed, he argued for "fairness"--that those who had done worse acts (i.e, those whose civil rights had been taken away) should not get the benefits of a reduced sentence (because they later had their rights restored), than those whose rights had never been taken away in the first place. It is sort of like the reverse of "older son" argument in the Parable of the Prodigal Son. Since he had never strayed from the father's will, he ought to get rewarded in ways that exceed the ways that the father rewarded the Prodigal. But it wasn't to be.

To the Court's Decision

Justice Ginsburg, speaking for a unanimous Court, argued in the following way. The bolded material below is taken from the Syllabus of the Argument put out by the Supreme Court Clerk's office:

The ordinary meaning of the word “restored”-giving back something that has been taken away-does not include retention of something never lost. Moreover, the context in which “restored” appears in § 921(a)(20) counsels adherence to the word's ordinary meaning. In § 921(a)(20), the words “civil rights restored” appear in the company of “expunged,” “set aside,” and “pardoned.” Each of those terms describes a measure by which the government relieves an offender of some or all of the consequences of his conviction. In contrast, a defendant who retains rights is simply left alone. He receives no status-altering dispensation, no token of forgiveness from the government.

The Court then rejected Logan's main argument against a "plain-meaning approach":

Logan's dominant argument against a plain-meaning approach is not persuasive. He relies on the harsh result a literal reading could yield: Unless retention of rights is treated as legally equivalent to restoration of rights, he maintains, less serious offenders will be subject to ACCA's enhanced penalties while more serious offenders in the same State, who have had civil rights restored, may escape heightened punishment. Logan urges that this result is not merely anomalous; it is absurd, particularly in States where restoration of civil rights occurs automatically upon release from prison.

Logan argued that the law as it is now has an anomaly. But the Court responded that the resolution he proposed would correct one potential anomaly while creating others.

Under Logan's proposed construction, all crimes, including first-degree murder, would be treated as crimes for which “civil rights [have been] restored” in a State that does not revoke any offender's civil rights, while less serious crimes committed elsewhere would not. Accepting Logan's argument would also undercut § 921(a)(20)(B), which subjects to ACCA state misdemeanor convictions punishable by more than two years' imprisonment. Because misdemeanors generally entail no revocation of civil rights, reading the word “restored” to include “retained” would yield this curiosity: An offender would fall within ACCA's reach if his three prior offenses carried potential prison terms of over two years, but would be released from ACCA's grip by virtue of his retention of civil rights.

Conclusion

I really think that a fourth grader could have come up with this answer to the question. Why did the Court spend its precious and limited judicial resources on the defining of such a term? Well, you got me...

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