Markell Anthony Coleman 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 First 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? This Court recently granted a petition for a writ of certiorari on the question of “whether the Second and Fourteenth Amendments guarantee the right to possess AR-15 platform and similar semiautomatic rifles.” Viramontes v. Cook County, No. 25-238 (June 30, 2026), see also Grant v. Higgins, No. 25-566 (June 30, 2026). Mr. Coleman entered a plea of guilty to a charge of possession of an unregistered machinegun. Factually, Mr. Coleman was in possession of a small metal object known as a conversion device which allows an AR-15 semi-automatic assault rifle to fire ten shots with one pull of a trigger. The Second Question Presented here is: Whether the Second and Fourteenth Amendments guarantee the right to possess an AR-15 platform semiautomatic rifle outfitted with a conversion device or a conversion device which allows an AR-15 platform semiautomatic rifle to shoot ten times with a single pull of the trigger?