Begay v. United States
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Sykes confined Begay's “purposeful, violent, and aggressive” inquiry to crimes akin to strict liability, negligence, and recklessness offenses. The Supreme Court later invalidated the Armed Career Criminal Act's residual clause in Johnson v. United States (2015) and expressly overruled Sykes's contrary judgment, while continuing to cite Begay's categorical approach. Most other opinions applied Begay, reported a different court's action, or rejected a party's proposed reading of it.
1,437 later cases cite Begay v. United States; 238 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Begay v. United States?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court treated risk as the usual measure under the Armed Career Criminal Act's residual clause and confined Begay's additional inquiry to crimes akin to strict liability, negligence, and recklessness offenses.
Sykes v. United States · Supreme Court of the United States · filed
As between the two inquiries, risk levels provide a categorical and manageable standard that suffices to resolve the case before us. Begay involved a crime akin to strict-liability, negligence, and recklessness crimes; and the purposeful, violent, and aggressive formulation was used in that case to explain the result.
Read the full opinion on CourtListener →
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