Abstract: On October 11, 2011, in United States v. Vann, the U.S. Court of Appeals for the Fourth Circuit, sitting en banc, held that Torrell Vann’s three prior indecent liberties convictions were not violent felonies under the federal Armed Career Criminal Act (ACCA). In so doing, the per curiam majority attempted to interpret the vague residual clause of the ACCA and concluded that taking improper liberties or committing lewd acts on the body of a child were not the type of convictions worthy of the fifteen-year mandatory minimum prison sentence mandated by the ACCA. This Comment argues that the time has come for Congress to amend the ACCA or for the U.S. Supreme Court to declare it void for vagueness, because an individual’s liberty cannot rest upon ad hoc judicial conjectures.
2015-2016 Board of Editors
We are pleased to announce the Board of Editors for the 2015-2015 academic year.
BCLR Latest Issue: Vol. LVI No. 3
The Boston College Law Review is pleased to announce our latest publication , the May 2015 issue. The current issue is featured on […]
BCLR Releases Vol. LV No. 3
The Boston College Law Review is pleased to publish the May 2014 issue. Here are summaries of this issue’s Articles and Notes: […]