Lockhart v. United States
United States Supreme Court
136 S. Ct. 958 (2016)
Avondale Lockhart (defendant), convicted of possessing child pornography, had a prior conviction for sexually assaulting his adult girlfriend; the mandatory minimum sentencing statute applied to anyone previously convicted of 'aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor.' The trial court read 'involving a minor' as modifying only the last item in that three-part list, meaning Lockhart's adult-victim assault conviction still triggered the ten-year mandatory minimum, and sentenced him accordingly; the appeals court agreed with that reading, and the Supreme Court granted certiorari to resolve whether the limiting phrase applied to just the final item or to the whole list.
Whether a limiting clause or phrase should be read as modifying only the noun or phrase it immediately follows, absent other indicia of meaning overcoming that interpretation.