short summary the case of Chambers v United States ?

can someone please in a short summary tell me what the chambers v. US was and what happened?

Thanks !

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  • 1 decade ago
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    In 2006, petitioner Deondery Chambers pled guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g). At sentencing, the government argued that petitioner was subject to a fifteen-year mandatory minimum sentence pursuant to § 924(e) of the Armed Career Criminal Act (ACCA), which requires such a sentence when a defendant violates § 922(g) after committing three “violent felon[ies] or [] serious drug offense[s].” One of the three “predicate convictions” on which the government relied to establish petitioner’s eligibility for the enhanced sentence was petitioner’s state conviction for escape. Under Illinois law, the term escape encompasses both breaking free from prison or custody and knowingly failing to report to prison. The government did not dispute that Chambers’ escape was in the latter category. Petitioner argued that his failure-to-report escape was not in fact violent because it did not present the kind of struggle that normally is present in escape from confinement and thus fell outside the purview of § 924(e).

    At the sentencing hearing, the district court relied on Seventh Circuit precedent to hold that escape constituted a “violent felony.” The court held that “for reasons of simplicity . . . escape is escape” and declined to differentiate between failure-to-report escape and custodial escape. Accordingly, the court concluded that Chambers was an armed career criminal and sentenced him to 188 months – a sentence at the bottom of the applicable Guidelines range. Had Chambers had not been treated as a career criminal, by contrast, his sentencing range would have been 130 to 162 months, with the statutory maximum for his offense at 120 months.

    On appeal, the Seventh Circuit, in an opinion by Judge Posner, framed the question before it as whether “a conviction under Illinois law for escape, was indeed a crime of violence.” “As an original matter,” the court observed, “one might have doubted whether failing to report to prison . . . was a crime that typically or often ‘involves conduct that presents a serious potential risk of physical injury to another.’” This, however, was not a question of first impression, and the court deemed itself bound by an earlier panel decision in United States v. Golden, holding that any escape under Illinois law constituted “a crime of violence [under] the Act.”

    The court then reviewed the other circuits’ positions on this question and concluded that the Seventh Circuit position was consistent with its sister circuits, except for the Ninth and D.C. Circuits. The court, however, indicated that “there would be no impropriety in dividing escapes, for purposes of ‘crime of violence’ classification, into jail or prison breaks on the one hand and . . . failures to report . . . on the other,” and that this division would be easy to apply for sentencing judges.

    Ultimately, the court decided to “adhere to the precedents for now“ but emphasized that “it is an embarrassment to the law when judges base decisions of consequence on conjectures, in this case a conjecture as to the possible danger of physical injury posed by criminals who fail to show up to begin serving their sentences

    Source(s): wikipedia
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