Watson v. United States
552 U.S. 74 (2007)
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Rule of Law:
A person does not "use" a firearm within the meaning of 18 U.S.C. § 924(c)(1)(A) when he receives it in a barter transaction in exchange for drugs.
Facts:
- Michael A. Watson told a government informant he wanted to acquire a gun.
- The informant suggested that Watson could pay for the gun with narcotics.
- Watson met with the informant and an undercover law enforcement agent who was posing as a firearms dealer.
- During the meeting, Watson gave the undercover agent 24 doses of oxycodone hydrochloride (OxyContin).
- In exchange for the drugs, Watson received a .50-caliber semiautomatic pistol from the agent.
- Watson later told law enforcement he acquired the pistol to protect his other firearms and drugs.
Procedural Posture:
- A federal grand jury indicted Michael A. Watson for distributing a controlled substance and for using a firearm during that crime in violation of § 924(c)(1)(A).
- In the federal trial court, Watson pleaded guilty to both charges but reserved his right to appeal the conviction under § 924(c)(1)(A).
- Watson appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed Watson's conviction based on circuit precedent.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the Circuit courts on the issue.
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Issue:
Does a person who trades drugs to receive a firearm "use" that firearm "during and in relation to any... drug trafficking crime" under 18 U.S.C. § 924(c)(1)(A)?
Opinions:
Majority - Justice Souter
No. A person who receives a firearm in exchange for drugs does not "use" the firearm within the ordinary meaning of the verb. The Court reasoned that statutory interpretation must begin with the ordinary and natural meaning of the language. In common speech, a person who trades an item (like drugs) to get another item (like a gun) is said to have "used" the first item, not the second. The Court distinguished this case from Smith v. United States, where it held that a person who gives a firearm in exchange for drugs does "use" the firearm. The Court rejected the government's argument for symmetry, stating that policy concerns cannot override the plain meaning of the statutory text and that it is Congress's role to amend the statute if it desires a different outcome.
Concurring - Justice Ginsburg
No. While agreeing with the judgment that Watson did not "use" the firearm, the concurrence argues the Court's precedent in Smith v. United States was wrongly decided. Justice Ginsburg asserted that the term "use" in § 924(c)(1) should be interpreted to mean use as a weapon only, not as an item of barter in a commercial transaction. Therefore, she would overrule Smith to create a more coherent and consistent legal standard, rather than distinguishing between giving and receiving a firearm in a trade.
Analysis:
This decision refines the definition of "use" under § 924(c)(1)(A), creating a clear distinction between giving a firearm for drugs and receiving one. It reinforces the Court's reliance on ordinary-language statutory interpretation, even if it leads to asymmetrical results where one party to a transaction is punished under the statute but the other is not. The opinion effectively directs prosecutors to use the statute's separate "possession in furtherance of" prong for future cases involving defendants who receive guns for drugs, narrowing the applicability of the "use" prong. The ruling highlights the Court's deference to Congress to resolve policy-based inconsistencies created by plain-text statutory readings.
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