Supreme Court of the United States
Dean v. United States
April 29, 2009556 U.S. 568
Summary
The Supreme Court held that 18 U.S.C. §924(c)(1)(A)(iii) does not require proof of intent for the 10-year mandatory minimum sentence for discharging a firearm during a crime of violence. The Court concluded the statutory text and structure demonstrate no intent requirement, and the rule of lenity does not apply absent grievous ambiguity. Justice Stevens and Justice Breyer dissented, arguing for a required intent element based on statutory structure, the presumption of mens rea, and the rule of lenity.