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
- 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.
- 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.