Lockhart v. United States (2016)

Lockhart v. United States, 577 U.S. ___ (2016), is a United States Supreme Court decision concerning the interpretation of a federal statute. 18 U.S.C. § 2252(b)(2) states that a defendant convicted of possessing child pornography is subject to a mandatory 10 year minimum prison sentence if they have "a prior conviction...under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward."[1] Avondale Lockhart, convicted of possession of child pornography, had a prior conviction for sexual abuse of his 53-year-old girlfriend under New York State law. He was sentenced to 10 years in prison under § 2252(b)(2). He appealed claiming that the qualifier "involving a minor or ward" applies to the whole series, making his prior conviction not trigger the sentence enhancement. In a 6-2 decision, the Supreme Court held that the phrase only modifies the final item in the series, upholding the 10 year minimum sentence imposed on Lockhart.[2]

Avondale Lockhart v. United States
Argued November 3, 2015
Decided March 1, 2016
Full case nameAvondale Lockhart v. United States
Docket no.14-8358
Citations577 U.S. ___ (more)
136 S. Ct. 958; 194 L. Ed. 2d 48; 84 U.S.L.W. 4112
Holding
The qualifier "involving a minor or ward" in 18 USC §2258(b)(2) applies only to the final item of the series, not the whole series. Lockhart's 10 year minimum sentence is thus valid under the statute.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajoritySotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Alito
DissentKagan, joined by Breyer
Laws applied
18 U.S.C. § 2252(b)(2)

See also

References
  1. 18 U.S.C. § 2252(b)(2).
  2. Lockhart v. United States, No. 14-8358, 577 U.S. ___, 136 S. Ct. 958 (2016).
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