Navigate

  •  

LOGAN v.UNITED STATES

On appeal from the Seventh Circuit Court of Appeals.

How did we get here?
James Logan plead guilty to being a felon in possession of a firearm. That’s all well and good, but he was sentenced to fifteen years in prison. He thought that his sentence was unfair, and he appealed.

What did the lower courts decide?
In 2005, Logan was convicted in Wisconsin Federal District Court. The Wisconsin district court sentenced Logan to fifteen years in prison. Mr. Logan had been convicted of unlawful possession of a controlled substance in 1991 (a Federal crime) and three convictions for misdemeanor battery (state crimes punishable by three years in prison).
Legal term: Battery - this crime is half of assault and battery and it is characterized by unconsensual punching, kicking, or biting: “an unlawful attack upon another person by beating or wounding, or by touching in an offensive manner.” Battery, as one might imagine, is among the oldest of crimes.

Mr. Logan appealed to the seventh circuit court of appeals. The seventh circuit ruled that the district court was right: It retained his sentence.

What did the Supreme Court decide?
The supreme court justices unanimously agreed with the district court and the court of appeals. Mr. Logan will spend fifteen years in prison, aside from parole.

If the Supreme Court was just gonna keep him in prison anyway, why did it take the case?
The lower courts appeal disagreed on cases like Mr. Logan’s. Those courts couldn't decide if the state crimes were aggravating factors for sentencing. The Supreme Court took the case to settle the disagreement.

What is this all about?
This case concerns guns, criminal prison sentences, and the practical consequence of calling a crime a "misdemeanor."

Here's an unsurprising fact: convicted criminals, namely felons, are not allowed to have guns.

Mr. Logan, a felon, got caught with a gun. He was also convicted of a state misdemeanor - three times.

To understand this case, you need to know the difference between felons and non-felons. Felons are criminals whose crimes can put them in prison for more than a year. Non-felons (as in everyone who has pleaded guilty to a speeding ticket) are criminals whose crimes can put them in prison for less than a year or not at all. Those crimes are classified as misdemeanors. However, not all crimes that punish criminals with more than a year in prison are felonies. States (like Wisconsin) may decide that they want to call a crime a misdemeanor, even when the state intends to put the convicted person in prison for more than a year.

Usually, felons are prevented from voting in elections, running for a political office, and serving on a jury. In other words, felons lose their civil rights and non-felons don't.

Congress takes a very dim view of felons who possess guns. It has established a 10 year minimum sentence for that crime (18 U. S. C. §924(a)(2)). Congress also decided that if one had been convicted of 3 violent felonies, then the minimum sentence for the crime is 15 years. Congress even decided that violent misdemeanor convictions count when the person could be sentenced to over 2 years in prison for the misdemeanor.

But, Congress did have some mercy on those who had thier civil rights "restored." Those with restored civil rights do not have to go to prison for 15 years - only 10. Mr. Logan was convicted of misdemeanors, so he never had his civil rights taken away. He thought that he should fall under this execption.

The Supreme Court disagreed - the statute says "restored." Restored means returned. There is a token of forgiveness from the government. In contrast, Mr. Logan was unforgiven. His misdemeanors didn't take away his civil rights, thus, he didn't have them restored.

Also, there wasn't any evidenece that Congress didn't mean for this to be the result. It passed a later law that did exaclty the same thing to people convicted of misdemeanor domestic violence. So, despite his protest that the result is unjust, Mr. Logan's sentence is 15 years in prison.

What's the quotable quote?
"Having no warrant to stray from §921(a)(20)’s text, we hold that the words 'civil rights restored' do not cover the case of an offender who lost no civil rights."

What's the life lesson?
If you are a felon, don't keep guns.

What's the big idea?
Congress wrote what it meant. The Supreme Court interpreted Congress' meaning by reading what Congress wrote. Just because the result is harsh, it doesn't mean that Congress didn't intend to be harsh.

Next case
© Clarinet Esq. | valid xhtml 1.0 | Design by wfiedler adapted by Clarinet Esq.