Lockhart v. United States

PETITIONER: Avondale Lockhart
RESPONDENT: United States
LOCATION: United States District Court for the Eastern District of New York

DOCKET NO.: 14-8358
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Second Circuit

CITATION: 577 US (2016)
GRANTED: May 26, 2015
ARGUED: Nov 03, 2015
DECIDED: Mar 01, 2016

ADVOCATES:
Ann O'Connell - Asisstant to the Solicitor General, for the respondent
Edward Scott Zas - for the petitioner

Facts of the case

In June 2010, undercover federal agents conducted an operation in which Avondale Lockhart ordered a number of videos containing child pornography. When the agents ostensibly delivered the ordered videos, they executed a search warrant and discovered over 15,000 images and at least nine videos depicting child pornography on Lockhart’s computer. Lockhart was subsequently charged with possession of child pornography, and he pled guilty. Lockhart had previously been convicted in state court of first-degree sexual abuse due to an incident involving his adult girlfriend. Based on this previous conviction, the pre-sentencing report for Lockhart’s child pornography sentencing recommended that Lockhart be subject to a mandatory minimum sentence. Lockhart argued that the mandatory minimum did not apply to him because the previous sexual offense did not involve a minor. The district court rejected Lockhart’s argument and held that the mandatory minimum sentence applied. The U.S. Court of Appeals for the Second Circuit affirmed the lower court’s decision.

Question

Does the mandatory minimum for a child pornography sentence apply when the defendant has previously been convicted of “aggravated sexual abuse” or “sexual abuse,” even when the previous conviction does not involve a minor?

Media for Lockhart v. United States

Audio Transcription for Oral Argument - November 03, 2015 in Lockhart v. United States

Audio Transcription for Opinion Announcement - March 01, 2016 in Lockhart v. United States

John G. Roberts, Jr.:

Justice Sotomayor has our opinion this morning in case number 14-8358, Lockhart versus United States.

Sonia Sotomayor:

This case comes to us on Writ of Certiorari to the Court of Appeals for the Second Circuit.

In 2000, petitioner Avondale Lockhart was convicted in New York state court of sexually abusing his adult girlfriend.

11 years later, he was convicted in federal court of possessing child photography in violation of 18 U.S.C. §2252.

Defendants convicted under that provision are subject to a sentencing enhancement if among other things 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.

This case concerns how to interpret the modifying clause at the end of that list involving a minor or ward.

Does it modify only the category of state crimes that immediately precedes it, abusive sexual conduct, that means as a result that the other two categories of state crimes do not need to involve a minor or ward or does it modify all three categories of state crimes and mean as a consequence that any prior state conviction whether for aggravated sexual abuse, sexual abuse or abusive sexual conduct must involve a minor or ward.

The Second Circuit held that it modifies only the last category of state crimes.

We affirm.

To reach that conclusion, we apply a timeworn interpretive strategy called the Rule of the Last Antecedent.

That rule provides that a limiting clause typically modifies only the noun or phrase that directly precedes it.

While the last antecedent rule can be overcome by other indicia of meaning; here we find that context only reinforces the interpretation it suggests.

For example the sentence enhancement can also be triggered by prior federal convictions for sexual abuse but the Federal sexual abuse crimes that trigger the enhancement can unequivocally involve adult in addition to minors and wards.

These federal crimes, moreover, are described in the US code using language very similar to the language used to describe the state crimes that trigger the enhancement.

Recognizing that similarity, the interpretation we adopt today ensures that the enhancement can be triggered by a prior state conviction for sexual abuse involving an adult just as it would if the prior conviction had been in federal court.

Justice Kagan has filed a dissenting opinion in which Justice Breyer joins.

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