Court rules on armed career criminal law
The Supreme Court ruled unanimously on Tuesday that the armed career criminal law’s sentence-enhancement provision applies to an individual who never lost his civil rights. Thus, the exemption from such an enhancement for those whose prior conviction has been set aside is not available if an individual’s status was never altered. The ruling came in Logan v. U.S. (06-6911), and was written by Justice Ruth Bader Ginsburg.
This was one of two rulings issued Tuesday. In the second, also decided unanimously, the Court ruled that the federal law that protects railroads from tax discrimination by states allows the carriers to challenge the accounting formulas states use to measure the value of rail property. Chief Justice John G. Roberts, Jr., wrote the opinion in CSX Transportation v. State Board of Equalization (06-1287).
The Logan case involved the interpretation of the phrase “civil rights restored” in the federal Armed Career Criminal Act. Those who have been convicted previously of felonies and are then convicted of possessing guns are subject to a maximum sentence of ten years, but that maximum is increased to life for those who have had three prior convictions for violent felonies — including violent misdemeanors. But Congress exempted from that enhancement feature those who have had their civil rights restored. James D. Logan of Janesville, Wis., was convicted of being a felon posseesing a gun and was sentenced to 15 years in prison, based upon three prior convictions for misdemeanor battery — a crime that causes no loss of civil rights. Logan argued that convictions that carry no loss of civil rights should be treated the same as those for which rights were lost then later restored. The Court rejected that claim. “Congress did not include offenders who retained civil righs at all times in its dispensation for offenders whose civil rigths have been restored,” Justice Ginsburg said. “We are not equipped to say what statutory alteration, if any, Congress would have made had its attention trained on offenders who retained civil rights.” And, she added, the Court cannot “recast” the law in a way that Congress did not.
The railroad case involved a 1976 federal law, the so-called “4-R Act,” that insulates railroads from tax discrimination by state governments. Tuesday’s decision overturned a ruling by the Eleventh Circuit Court that barred railroads from challenging anything but the factual determinations in state valuations, excluding all other factors, including the accounting formula used. To apply the Act, federal judges must calculate the true market value of the property that a railroad has in the taxing state. The Court said that the true market value may be affected by the valuation method that a state chooses, and, if railroads could not challenge such methods, states could use appraisal techniques that “routinely overestimate the market worth of railroad assets.”