Summary: Johnson V. United States

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Samuel James Johnson v. United States, better known as Johnson v. United States, is a landmark case that questioned the constitutionality of the Armed Career Criminal Act (ACCA) under the due process clause of the 5th Amendment. Samuel James Johnson challenged that the qualifications of the Armed Career Criminal Act’s definition of a “violent felony” were too vague, therefore making the ACCA unconstitutional. The court ruled 8 – 1 in favor of Johnson, imposing that an increased sentencing under the ACCA’s unconstitutionally vague residual clause violates the due process clause of the 5th Amendment. The facts of the case are that follows. The Federal Bureau of Investigation (FBI) was investigating Samuel James Johnson for his involvement into an organization called the National Social Movement. Johnson later left the National Social Movement, and formed his own group called the Aryan Liberation Movement. The FBI continue their undercover investigation and was able to get Johnson to tell an undercover agent that he manufactured silencers, napalm, and other explosives within the Aryan Liberation …show more content…
The court ruled 8 – 1 in favor of Johnson, with Justice Antonin Scalia delivering the majority opinion. Scalia claimed the court held that the residual clause of the Armed Criminal Career Act (ACCA) is unconstitutionally vague. The court cited Kolender v. Lawson (1983) statue that people must be given a fair notice of the conduct it punishes, and claimed that the law did not give this fair notice or was enforced logically without violating due process. Justice Scalia continued and said that because the ACCA does not give guidelines for the court to assess what conduct poses a “serious potential risk of physical injury”, it leads to unpredictable and arbitrary enforcement in violation of due process. Precedent was not to be upheld during this case because the court had decided that judicial interpretation of the residual clause was not sufficiently