This note will first explain the facts of Custis' case and then discuss the background of the Armed Career Criminal Act. The ACCA discussion will be followed by a review of the procedural history and the Supreme Court's analysis of Custis' case. The note will then offer a critique of the Court's interpretation of the language and legislative intent behind the ACCA. Finally, the note will conclude that the Custis decision illustrates increasing judicial effort to curtail the availability of post-conviction relief formerly available to criminal defendants.
Barry W. Strike,
Custis v. United States: Are Unconstitutional Prior Convictions Being Used to Increase Prison Terms?, 25 Golden Gate U. L. Rev.