Castillo v. United States

PETITIONER: Castillo
RESPONDENT: United States
LOCATION: FBI Field Office

DOCKET NO.: 99-658
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 530 US 120 (2000)
ARGUED: Apr 24, 2000
DECIDED: Jun 05, 2000

ADVOCATES:
James K. Robinson - Department of Justice, argued the cause for the respondent
Stephen P. Halbrook - Argued the cause for the petitioners

Facts of the case

In 1993, Jaime Castillo and other Branch-Davidians were involved in a violent confrontation with federal agents near Waco, Texas. Castillo was indicted for conspiring to murder federal officers. A jury determined that Castillo, by using firearms in connection with the alleged conspiracy, had violated 18 USC Section 924(c)(1), which read in relevant part: "Whoever, during and in relation to any crime of violence... uses or carries a firearm, shall, in addition to the punishment provided for such crime... be sentenced to imprisonment for five years... and if the firearm is a machinegun... to imprisonment for thirty years." During sentencing, the District Court found that Castillo had possessed machineguns and imposed the mandatory 30-year prison sentence. On appeal, the Courts of Appeals remanded the case to the District Court for a determination of whether Castillo had used, rather than merely possessed, machineguns. The court also concluded that statutory terms such as "machinegun" did not state elements of a crime separate from that of using a firearm, but instead established factors enhancing a sentence and that the District Court could reimpose the 30-year sentence if it found that machineguns had been actively used. The District Court then reimposed the 30-year sentence, and the Court of Appeals affirmed.

Question

Does the provision of USC Section 924(c)(1), which imposes a stiffer penalty for using a "machinegun" in a crime of violence, state factors enhancing a sentence rather than elements of a separate offense?

Media for Castillo v. United States

Audio Transcription for Oral Argument - April 24, 2000 in Castillo v. United States

Audio Transcription for Opinion Announcement - June 05, 2000 in Castillo v. United States

William H. Rehnquist:

The opinion of the Court in No. 99-658, Castillo against United States will be announced by Justice Breyer.

Stephen G. Breyer:

This case focuses on a federal criminal statute that prohibits the use or carrying of a “firearm” during or in relation to a crime of violence.

The statute says that in addition to the punishment provided for the underlying crime of violence the offender “shall be sentenced to imprisonment for five years if he uses or carries a firearm", then it adds, "and if the firearm is a machinegun, to imprisonment for 30 years."

The question is whether that statutory word “machinegun” or various other kinds of specifically listed firearm types, whether it designates a separate crime in which case the government has to charge the element machinegun in an indictment and prove it to a jury beyond a reasonable doubt, or whether it simply sets forth a sentencing factor i.e. a reason for increasing the sentence which a judge not the jury would determine.

We recently considered similar questions involving other statutes in cases called Jones v. United States and Almendarez-Torres v. United States, both of which involved discussions of statutory interpretation as well as Congress’ power under the constitution to permit judges rather than juries to determine particular factual matters.

In this case however we do not invoke the constitutional principles rather we simply use traditional tools of statutory analysis considering language, structure, context, and history of the statute along with such other factors as typically help a court to determine what Congress’ intent was, and we conclude that Congress intended the factual matter at issue whether, what the offender used was a machinegun, but it intended that to be an element of a separate crime, not the sentencing factor.

That being so where the government seeks the mandatory 20 or 30-year prison sentences prescribed by the statute for certain firearm types the government has to charge the type of firearm as an element in the indictment and prove it to a jury beyond a reasonable doubt.

We reverse the judgment of the Federal Court of Appeals below which had reached the different conclusions.

We explained all this in considerably greater detail in our opinion, and except for the discussion of legislative history which appears in part two of the opinion which Justice Scalia does not join; with that exception our decision is unanimous.