Lockhart v. United States (2016)

Lockhart v. United States, 577 U.S. 347 (2016), is a United States Supreme Court decision concerning the interpretation of a federal statute. 18 U.S.C. § 2252(b)(2) states that a defendant convicted of possessing child pornography is subject to a mandatory 10 year minimum prison sentence if they have "a prior conviction...under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward." Avondale Lockhart, convicted of possession of child pornography, had a prior conviction for sexual abuse of his 53-year-old girlfriend under New York State law. He was sentenced to 10 years in prison under § 2252(b)(2). He appealed claiming that the qualifier "involving a minor or ward" applies to the whole series, making his prior conviction not trigger the sentence enhancement. In a 6-2 decision, the Supreme Court held that the phrase only modifies the final item in the series, upholding the 10 year minimum sentence imposed on Lockhart.