Criminal Law—First Circuit Upholds Constitutionality of Juvenile Convictions as Predicate Offenses Under the Armed Career Criminal Act—United States v. Matthews, 498 F.3d 25 (1st Cir. 2007)

First Circuit Review 2008

The Armed Career Criminal Act (ACCA) is a recidivist statute that punishes repeated criminal behavior.  Specifically, the ACCA enhances the minimum penalty for those who unlawfully possess firearms and have a history of prior felony convictions.  To constitute a predicate felony conviction under ACCA, the prior convictions must have resulted from a crime involving violence or a serious drug offense.  In United States v. Matthews, the United States Court of Appeals for the First Circuit considered whether using a criminal defendant’s prior juvenile adjudication as a sentencing enhancement under the ACCA offends the Constitution.  The First Circuit held that the ACCA’s sentencing enhancement based on prior juvenile adjudications does not violate a defendant’s right to due process of law. . . .