Lockhart v. United States (2016)

Lockhart v. United States, 577 U.S. 347 (2016), is a United States Supreme Court decision concerning the interpretation of a federal statute. 18 U.S.C. § 2252(b)(2) states that a defendant convicted of possessing child pornography is subject to a mandatory 10 year minimum prison sentence if they have "a prior conviction...under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward."^[1] Avondale Lockhart, convicted of possession of child pornography, had a prior conviction for sexual abuse of his 53-year-old girlfriend under New York State law. He was sentenced to 10 years in prison under § 2252(b)(2). He appealed claiming that the qualifier "involving a minor or ward" applies to the whole series, making his prior conviction not trigger the sentence enhancement. In a 6-2 decision, the Supreme Court held that the phrase only modifies the final item in the series, upholding the 10 year minimum sentence imposed on Lockhart.^[2]

Avondale Lockhart v. United States
Supreme Court of the United States
Argued November 3, 2015 Decided March 1, 2016
Full case name	Avondale Lockhart v. United States
Docket no.	14-8358
Citations	577 U.S. 347 (more) 136 S. Ct. 958; 194 L. Ed. 2d 48; 84 U.S.L.W. 4112
Holding
The qualifier "involving a minor or ward" in 18 USC §2258(b)(2) applies only to the final item of the series, not the whole series. Lockhart's 10 year minimum sentence is thus valid under the statute.
Court membership
Chief Justice John Roberts Associate Justices Anthony Kennedy · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer Samuel Alito · Sonia Sotomayor Elena Kagan
Case opinions
Majority	Sotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Alito
Dissent	Kagan, joined by Breyer
Laws applied
18 U.S.C. § 2252(b)(2)

See also

• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Roberts Court