Dean v. United States

Summary

Chief Justice Roberts, joined by Justices Scalia, Kennedy, Souter, Thomas, Ginsburg, and Alito, held that 18 U.S.C. §924(c)(1)(A)(iii) requires no separate proof of intent to discharge a firearm: its ten-year mandatory minimum applies to accidental as well as intentional discharges during the specified crimes. The statutory text and structure also foreclose applying the rule of lenity. The Court affirmed the Eleventh Circuit. Justice Stevens dissented without joiners, reasoning that the escalating penalties, legislative history, and presumption of mens rea require intentional discharge. Justice Breyer separately dissented without joiners, emphasizing statutory ambiguity and the special force of lenity when interpreting mandatory minimum sentences. Outside confirmation was unavailable; this analysis rests on the supplied opinion text.