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Dean v. United States | 556 U.S. 568 (2009)
The forgiving expression accidents happen is usually reserved for minor mistakes, like spilling a drink, not something as dangerous as an unintentional discharge from a gun. In Dean versus United States, the Supreme Court answered whether a person’s sentence should be enhanced if a gun accidentally discharges during a crime.
In two thousand four, Christopher Dean robbed a bank in Georgia. During the robbery, Dean wore a mask, waved a gun, and demanded that everyone in the bank get on the floor. Dean went behind the teller’s stations and began grabbing bills with his left hand as he continued to hold his gun in his right hand. As Dean was grabbing money, his gun discharged and shot a bullet through the teller window. Dean cussed after the gun discharged and quickly left the bank. Witnesses testified that Dean seemed surprised when the gun discharged. No one was shot or physically hurt during the robbery.
The United States charged Dean with conspiracy to commit a robbery affecting interstate commerce and carrying, possessing, and discharging a firearm during an armed robbery. A jury found Dean guilty on both the robbery and firearm counts. A federal law adds mandatory sentence enhancements if a defendant uses or carries a firearm during a violent crime. Under the law, a defendant would be sentenced to five additional years if he or she had a gun at the time of the crime. If a firearm is brandished, then seven additional years are added to the sentence. Finally, if, quote, “the firearm is discharged,” unquote, the mandatory minimum sentence is ten years. The district court sentenced Dean to the mandatory minimum ten year sentence for the firearm count because the gun discharged during the robbery. Dean appealed. Dean argued that the law required proof that the defendant intended to discharge the gun. Therefore, Dean claimed that the sentence enhancement didn’t apply because the discharge from his gun was accidental. The court of appeals affirmed the district court’s ruling and held that the law didn’t require any proof of intent to discharge a gun. The Supreme Court granted cert to resolve a conflict among circuit courts on the issue.
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