Jamaal A. Hameen v. United States

I. In Erlinger v. United States, 602 U.S. 821 (2024), this Court held that the Fifth and Sixth Amendments require the government to prove the Armed Career Criminal Act’s (“ACCA”) complex differentoccasions requirement to a jury beyond a reasonable doubt. Is Erlinger error structural? II. The Eleventh Circuit determined Erlinger error was harmless in Petitioner Jamaal Hameen’s case by relying on contested facts from the Presentence Investigation Report (“PSR”) that were not admitted at trial and were not adopted by the district court at sentencing. Did the appellate court err by conducting harmless-error review based on these facts? III. To determine whether a prior state conviction qualifies as an ACCA predicate, federal courts take a categorical approach and consider the elements of the state offense. When Mr. Hameen was convicted of aggravated assault, Florida appellate courts affirmed such convictions for reckless conduct. Decades after Mr. Hameen’s conviction, the Florida Supreme Court decided this offense required at least knowing conduct. Did the Eleventh Circuit err in relying on a Florida Supreme Court decision issued decades after Mr. Hameen’s state conviction to decide his aggravated assault was an ACCA predicate?1 IV. Does 18 U.S.C. § 922(g)(1) exceed Congress’s authority under the Commerce Clause, facially and as applied to Mr. Hameen’s intrastate firearm possession? 2 1 The question of whether federal courts should consult state decision in place at the time of a defendant’s prior conviction or the most recent state court decision to determine the elements of a prior conviction for purposes of applying ACCA’s category approach is pending in Leland v. United States, No. 25-12739 (response requested on Aug. 19, 2026). 2 This Commerce Clause question is pending in Stewart v. United States, No. 26-5131 (response filed Sept. 21, 2026); and Antunez-Galarza v. United States, No. 26-5188 (response filed Sept. 30, 2026).