Custis v. United States
511 U.S. 485 (1994)
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Rule of Law:
A defendant may not collaterally attack the validity of prior state convictions used for sentence enhancement under the Armed Career Criminal Act during the federal sentencing hearing, unless the challenge is based on the complete denial of the right to counsel.
Facts:
- Darren J. Custis had a 1985 Pennsylvania state-court conviction for robbery.
- Custis also had a 1985 Maryland state-court conviction for burglary, which he later claimed was the result of an unknowing guilty plea and ineffective assistance of counsel because his attorney failed to advise him of a potential defense.
- Custis obtained a third prior conviction in 1989 in Maryland for attempted burglary, which resulted from a 'stipulated facts' trial that he claimed was functionally a guilty plea entered without proper advisement of his rights.
- On July 1, 1991, Baltimore City Police arrested Custis.
- During his arrest and subsequent investigation, Custis was found to be in possession of a firearm.
Procedural Posture:
- A federal grand jury indicted Darren J. Custis for possession of a firearm by a convicted felon and other charges.
- The Government notified Custis it would seek an enhanced penalty under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior felony convictions.
- A jury in the U.S. District Court for the District of Maryland convicted Custis of being a felon in possession of a firearm.
- At the sentencing hearing, Custis attempted to collaterally attack two of his prior Maryland convictions, arguing they were constitutionally invalid.
- The District Court ultimately ruled that Custis could not challenge the validity of his prior convictions during the federal sentencing proceeding and imposed an enhanced sentence.
- Custis, as appellant, appealed to the U.S. Court of Appeals for the Fourth Circuit.
- The Court of Appeals affirmed the District Court's decision, holding that collateral attacks were barred except for claims of complete denial of counsel.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts on this issue.
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Issue:
Does the Armed Career Criminal Act, 18 U.S.C. § 924(e), permit a defendant in a federal sentencing proceeding to collaterally attack the constitutional validity of the prior state convictions used to enhance his sentence?
Opinions:
Majority - Chief Justice Rehnquist
No. The Armed Career Criminal Act does not permit a defendant to collaterally attack prior convictions during a federal sentencing proceeding, with the sole exception of convictions obtained in complete denial of the right to counsel. The text of § 924(e) focuses on the mere fact of a prior conviction and, unlike other federal statutes that explicitly permit such challenges (e.g., 21 U.S.C. § 851(c)), provides no statutory mechanism for doing so. Constitutionally, while precedent from Burgett v. Texas and United States v. Tucker allows challenges to prior convictions obtained in violation of the right to counsel established in Gideon v. Wainwright, that right is unique. The Court has historically treated the failure to appoint counsel as a 'jurisdictional defect,' a special status not afforded to other constitutional claims like ineffective assistance of counsel or invalid guilty pleas. Furthermore, allowing broader challenges would create significant administrative burdens on sentencing courts and undermine the finality of state court judgments.
Dissenting - Justice Souter
Yes. The Armed Career Criminal Act should be interpreted to authorize sentence enhancement based only on prior convictions that are lawfully obtained, thereby permitting a defendant to show at sentencing that a prior conviction was unconstitutional. The term 'conviction' in the statute should be read to mean 'lawful conviction,' consistent with the legal backdrop established by Burgett v. Texas and United States v. Tucker when the ACCA was enacted. The majority's statutory interpretation relies on weak negative inferences and misapplies precedent like Lewis v. United States. By construing the statute to bar these challenges, the Court unnecessarily creates and decides a difficult constitutional question, violating the doctrine of constitutional avoidance. The rule of lenity and considerations of judicial efficiency also support interpreting the statute in the defendant's favor, as the administrative burdens are overstated.
Analysis:
This decision significantly narrows the ability of federal defendants to challenge the constitutional underpinnings of prior convictions used for sentencing enhancements under the ACCA. By creating a bright-line rule that only Gideon claims (complete denial of counsel) can be raised at sentencing, the Court prioritized finality and administrative efficiency over a defendant's ability to contest other serious constitutional defects, such as ineffective assistance of counsel or coerced guilty pleas. This holding forces defendants to challenge such convictions through separate, often more procedurally complex and time-barred, state or federal habeas corpus proceedings. The ruling solidifies the unique, foundational status of the right to counsel as a 'jurisdictional' right in the context of collateral attacks.
