United States v. Miller
Case Overview
Justin Miller was sentenced under the Armed Career Criminal Act based in part on prior state drug convictions. The Supreme Court addressed whether the categorical approach requires courts to compare a state drug schedule against the federal schedule as they existed at the time of the prior conviction, resolving a circuit split on the timing of that comparison.
BrynoDC Coverage 1 video
The Facts
Miller had prior state drug convictions that the sentencing court treated as qualifying predicates under ACCA's serious-drug-offense definition. At the time of those convictions, the relevant state drug schedule included substances not listed on the federal controlled substances schedule, meaning the state offense was categorically broader than its federal counterpart. The question was whether the comparison should be made as of the time of the prior conviction or the time of federal sentencing.
The Application
Miller's prior state drug convictions occurred at a time when his state's controlled-substance schedule included compounds the federal government had not scheduled, making the state offense categorically broader than its federal counterpart. Under the conviction-time comparison approach established in this case, this breadth means the state conviction cannot categorically align with the federal serious-drug-offense definition required for ACCA. Accordingly, the sentencing court's reliance on these prior convictions to impose the 15-year mandatory minimum was improper, warranting resentencing.
The Conclusion
**Miller resolves a circuit split by anchoring the categorical comparison to the time of the prior conviction.** Where a state drug schedule was broader than the federal schedule at the time of conviction, the state conviction does not categorically qualify as an ACCA predicate. Because many states historically scheduled substances more broadly than the federal government, the ruling may require resentencing for a substantial number of defendants serving ACCA-enhanced sentences.
No circuit court data for this case.
Flag an issue
This tracker is maintained by BrynoDC and is free because readers fund it. Support