## Facts

- Keith Jerome Custis was convicted in federal court of being a felon in possession of a firearm and another federal offense in the same proceeding.
- The United States sought an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior state convictions (one robbery and two burglary-related convictions).
- At federal sentencing, Custis attempted to collaterally challenge two predicate convictions, alleging constitutional defects including ineffective assistance of counsel and unknowing or involuntary guilty pleas.
- The district court declined to consider those challenges, allowing collateral review only for a conviction obtained through a complete denial of counsel.
- Custis received an ACCA-enhanced sentence of 235 months; the court of appeals affirmed.

## Issues

1. Whether ACCA or the Constitution permits a defendant, during an ACCA sentencing proceeding, to collaterally attack prior state convictions used for enhancement on grounds other than a complete denial of counsel.
2. Whether claims such as ineffective assistance of counsel or involuntary guilty pleas may be litigated at federal sentencing to prevent use of prior convictions as ACCA predicates.

## Decision

- The Supreme Court affirmed.
- ACCA does not provide a statutory right to collaterally attack predicate convictions at sentencing.
- The Constitution requires sentencing courts to disregard predicate convictions only when the prior conviction was obtained in violation of the right to counsel (a Gideon-type complete denial of counsel).
- Collateral attacks based on ineffective assistance of counsel, involuntary pleas, and similar constitutional claims may not be raised in the ACCA sentencing proceeding.
- A defendant who later succeeds in vacating predicate convictions through state post-conviction relief or federal habeas may then seek reopening of an enhanced federal sentence.

## Legal Principles

- ACCA’s requirement that a defendant “has three previous convictions” does not authorize collateral litigation over alleged constitutional errors in those convictions at the federal sentencing hearing.
- A federal sentencing court must permit collateral attack on a predicate conviction only for a prior conviction obtained through a complete denial of the Sixth Amendment right to counsel.
- Finality and administrability concerns support limiting collateral attacks at sentencing; denial-of-counsel claims are generally ascertainable from the record, while other claims typically require extensive fact development.
- Broader challenges to predicate convictions must be pursued in the convicting jurisdiction’s courts or through habeas review; successful vacatur may support later modification of the enhanced federal sentence.

## Conclusion

The Court held that, in ACCA sentencing, a defendant may not collaterally attack prior state convictions used for enhancement except where the predicate conviction resulted from a complete denial of counsel; other constitutional challenges must be brought in separate post-conviction proceedings and, if successful, may support later reopening of the enhanced federal sentence.


Custis v. United States, 511 U.S. 485 (1994)