Jacklin Cheramy v. United States

In Brown v. United States, 602 U.S. 101 (2024), this Court held that whether a prior state drug trafficking conviction qualified as a predicate under the Armed Career Criminal Act in a federal prosecution required a review of the state conviction at the time of the conviction. However, this Court expressly left open the question of whether a federal sentencing court must review the state conviction at the time of the federal sentencing, rather than at the time of the conviction, for a recidivist enhancement under the United States Sentencing Guidelines given the requirement that the Sentencing Guidelines in effect at sentencing must be applied. The Question Presented here is: Whether, consistent with federal statute mandating the application of the United States Sentencing Guidelines in effect at the time of sentencing, a sentencing court must look to the validity of a state prior at the time of federal sentencing to determine whether the state conviction qualifies as a predicate offense for a recidivist sentencing enhancement under the United States Sentencing Guidelines?