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.