In Abbott v. United States, Court uses title of a statute to interpret it

November 15th, 2010

In Abbott v. United States, the Court sought to resolve a circuit split over the interpretation of 18 U.S.C. 924(c). The title of the act was “An Act [t]o throttle criminal use of guns, 112 Stat. 3469.” As part of the analysis, the Court looked to the title of the relevant statute to ascertain legislative intent:

As earlier observed, see supra, at 5–6, the pre-1998 version of §924(c) prescribed a discrete sentence—punishment to be imposed regardless of the sentence received for the predi-cate crime or any separate firearm conviction. Abbott and Gould think the “except” clause installed, instead, a mod-est scheme designed simply to ensure that all §924(c) offenders “serve at least 5 years in prison.” Gould Brief 5; see Abbott Brief 10. We doubt that Congress meant aprefatory clause, added in a bill dubbed “An Act [t]o throt-tle criminal use of guns,” to effect a departure so greatfrom §924(c)’s longstanding thrust, i.e., its insistence that sentencing judges impose additional punishment for§924(c) violations.

Once in class, I commented that some case construed the Anti-Terrorism and Effective Death Penalty Act (AEDPA) improperly. I noted that the Court’s interpretation made it really really tough to impose the death penalty, so the case went against the congressional purpose of making the death penalty effective. I don’t think I really bought the argument, but it was the best I could come up with. I recall the Professor told me that it is a poor cannon of construction to look at the title of a statute to find purpose. Huzzah! Vindicated by SCOTUS!