This Comment explores the U.S. Supreme Court’s attempt to create a judicial standard for defining the term “violent felony” that embodies the purpose of the ACCA and its ultimate failure to do so. Part II presents a brief background on the ACCA. Part III discusses United States v. James, Begay v. United States, and United States v. Chambers—three recent Supreme Court decisions that suggest the Court’s analyses are flawed. Part IV examines opportunities for the Court and Congress to remedy the situation, including a critique of each proposal.
Hayley A. Montgomery, Remedying the Armed Career Criminal Act’s Ailing Residual Provision, 33 SEATTLE U. L. REV. 715 (2010).