Jones v. United States - 526 U.S. 227, 119 S. Ct. 1215 (1999)

Rule:

Any doubt on the issue of statutory construction is hence to be resolved in favor of avoiding serious constitutional questions. This is done by construing 18 U.S.C.S. § 2119 as establishing three separate offenses by the specification of distinct elements, each of which must be charged by indictment, proven beyond a reasonable doubt, and submitted to a jury for its verdict. The judgment of the Court of Appeals is accordingly reversed, and the case is remanded for proceedings consistent with this opinion.

Facts:

Petitioner was convicted of carjacking pursuant to 18 U.S.C.S. § 2119. Petitioner's sentence was enhanced under § 2119(2), for causing serious bodily injury. Petitioner alleged the § 2119(2) was a distinct offense for which petitioner was not indicted and for which the elements were not proven. Respondent government alleged that § 2119's subsections were sentencing factors, not elements that respondent was required to prove. The trial court and appellate court agreed with respondent and held that § 2119(2) was a sentencing factor. Petitioner sought certiorari review.

Issue:

Did § 2119 establish three separate offenses with different elements? 

Answer:

Yes.

Conclusion:

The Court reversed and held that § 2119 established three separate offenses with different elements. Respondent was required to specify each of the elements in the indictment and to prove the elements beyond a reasonable doubt to a jury. The statute was subject to reasonable interpretation and, therefore, was construed to avoid constitutional questions. The fairest reading treated serious bodily harm as an element, not a sentencing factor. Otherwise, the jury's significance was diminished and caused U.S. Const. amend. VI concern. Serious bodily injury was traditionally an element required to be set out in the indictment.