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Supreme Court Limits Dual Convictions Under Overlapping Federal Gun Statutes

In a unanimous ruling, the Court said Congress must clearly authorize multiple punishments for one act before prosecutors can obtain separate convictions under overlapping laws.

Overview

  • The Court held that a single act violating both 18 U.S.C. §§ 924(c)(1)(A)(i) and 924(j) can result in only one conviction, reversing part of the Court of Appeals’ judgment and remanding Barrett’s case.
  • Applying the Blockburger elements test, the justices concluded the provisions do not each require proof of a distinct element and lack clear congressional authorization for cumulative punishments.
  • The case arose from Dwayne Barrett’s 2011–2012 robberies, during which a confederate killed Gamar Dafalla, and prosecutors secured convictions under both provisions for the same conduct.
  • The decision resolves a split among federal appellate courts and curtails prosecutors’ ability to stack overlapping § 924 counts for a single act, affecting charging and sentencing practices.
  • Justice Neil Gorsuch concurred to highlight longstanding confusion in the Court’s Double Jeopardy jurisprudence and suggested further clarification may be needed.