Brown v. United States

In Brown v. United States, the U.S. Supreme Court addressed whether a prior state drug conviction qualifies as a "serious drug offense" under the Armed Career Criminal Act when the state's definition of cocaine includes optical and positional isomers not covered by the federal Controlled Substances Act. Petitioner Justin Brown was convicted of federal firearm possession and received a 15-year mandatory minimum based on prior Pennsylvania cocaine convictions. The Court held 6-3 that the state offense did not match the federal definition, vacated the sentence, and remanded.

The Supreme Court reversed the Third Circuit, holding 6-3 that Pennsylvania's cocaine offense is broader than the federal definition and thus cannot serve as an ACCA predicate. Justice Alito wrote the majority; Justice Jackson filed a dissent joined by Justices Sotomayor and Kagan.

Whether the ACCA's "serious drug offense" definition requires a categorical match between state and federal controlled substance definitions, particularly regarding cocaine isomers.

Narrows ACCA application, potentially reduces mandatory minimum sentences for federal firearm offenders with prior state drug convictions that define controlled substances more broadly than federal law; highlights importance of statutory precision in federal sentencing enhancements.