Borden v. United States

Borden v. United States centered on Charles Borden Jr., who pleaded guilty to being a felon in possession of a firearm. The government sought an enhanced sentence under the Armed Career Criminal Act (ACCA), arguing his prior Tennessee aggravated assault conviction qualified as a violent felony. ACCA imposes a 15-year mandatory minimum for defendants with three prior violent felony convictions. The key question was whether a criminal offense requiring only a mens rea of recklessness—rather than knowledge or intent—could constitute a violent felony under ACCA's elements clause. The district court applied the enhancement, and the Sixth Circuit affirmed. The Supreme Court granted certiorari to resolve a circuit split on this statutory interpretation issue.

In a 5-4 decision, the Supreme Court reversed the Sixth Circuit. Justice Kagan, writing for the majority, held that a criminal offense with a mens rea of recklessness does not qualify as a violent felony under ACCA's elements clause. The Court reasoned that the phrase "use of physical force against the person of another" requires a purposeful or knowing state of mind, not mere recklessness. Justice Thomas concurred in the judgment. Justice Kavanaugh dissented, joined by Chief Justice Roberts and Justices Alito and Barrett.

Whether a criminal offense that can be committed with a mens rea of recklessness qualifies as a "violent felony" under the elements clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i).

The decision narrowed the scope of the Armed Career Criminal Act, reducing the number of prior offenses that can trigger mandatory minimum 15-year sentences. Criminal defense attorneys and sentencing reform advocates praised the ruling for limiting excessive punishment based on reckless conduct. Prosecutors expressed concern about its impact on public safety. The ruling resolved a significant circuit split, providing nationwide uniformity in federal sentencing, and reinforced the principle that enhanced penalties require a showing of intentional or knowing violent conduct rather than accidental or reckless behavior.