Archive | 924(j)

Monday, March 3rd, 2025

Supreme Court takes Second Circuit case to decide if defendants can be constitutionally punished under both § 924(c) and § 924(j)

The Supreme Court has granted certiorari in Barrett v. United States, No. 24-5774, to decide if the Double Jeopardy Clause permits a court to impose separate sentences for an act that violates both 18 U.S.C. § 924(c) and § 924(j). The petition is available here.

Section 924(c)(1)(A) is violated if someone, “during and in relation to any crime of violence or drug trafficking crime . . . , uses or carries a firearm, or [], in furtherance of any such crime, possesses a firearm.” Section 924(j) is violated if someone, “in the course of a violation of subsection (c), causes the death of a person through the use of a firearm.”

Most circuits to address the issue have held that § 924(c) is a lesser included offense of § 924(j), meaning that, under the Double Jeopardy Clause, a defendant may not be constitutionally punished for both offenses. The …


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Categories: 924(c), 924(j), double jeopardy

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Friday, June 23rd, 2023

Supreme Court holds that a 924(j) conviction does not require a consecutive sentence.

In Lora v. United States, decided June 16, 2023, the Supreme Court ruled that the bar on imposition of concurrent sentences in 18 U.S.C. 924(c)(1)(D)(ii) does not apply to a sentence for a 924(j) conviction.  Thus, the district court has the discretion to run a 924(j) sentence either concurrently with or consecutively to a sentence for another offense.

The Court reasoned that by its terms the consecutive sentence mandate of 924(c) is limited to sentences imposed “under this subsection.”  Quite obviously, 924(j) is a separate subsection.  It incorporates some of the offense elements of 924(c) but not its penalty provision.  Accordingly, the concurrent sentences bar of 924(c) does not apply to a sentence imposed under 924(j).

This decision unanimously reversed the Second Circuit in an opinion by Justice Jackson.…

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Categories: 924(c), 924(j)

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Categories: 924(c), 924(j)

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