Shular v. United States

Summary

Justice Ginsburg delivered the unanimous Court’s opinion affirming the Eleventh Circuit. The Court held that ACCA’s definition of a state-law “serious drug offense” requires determining whether the offense’s elements necessarily entail the conduct specified in 18 U.S.C. §924(e)(2)(A)(ii), not comparing those elements with the elements of generic drug offenses. The statutory text and context resolved the question without resort to the rule of lenity. The Court did not decide Shular’s alternative argument that the specified conduct itself requires knowledge of the substance’s illicit nature. Justice Kavanaugh concurred separately, without any other Justice joining, emphasizing that lenity applies only after all traditional interpretive tools have been exhausted and grievous ambiguity remains.