Dean v. United States — Breyer, J., dissenting

Summary

Justice Breyer dissents, arguing that the mandatory minimum enhancement under 18 U.S.C. § 924(c)(1)(A)(iii) applies only to intentional firearm discharges, not accidental ones. He relies on Bailey v. United States and the rule of lenity, noting that mandatory minimums amplify the harm of erroneous inclusion. Justice Stevens also dissents, relying on statutory structure and the presumption of mens rea.