One Act, One Sentence, One Opinion

Xylee Alvarez

February 2026 

The Justices' 9-0 ruling in Barrett v. United States reveals their opinions on punishment and its limits. 

Barrett v. United States was a case in which every justice agreed, which intrigues me because such cases require the Court to explain why a line exists, not simply where it is drawn. Rather than arguing over guilt or innocence, the justices focused on something more foundational in their opinion: whether the federal government can turn one act into multiple convictions simply by stacking statutes on top of each other.

The case centered on two federal statutes, 18 U.S.C. § 924(c) and§ 924(j), both of which impose severe penalties when a firearm is used during a violent crime. Barrett was convicted under BOTH provisions for a single act, which brings us to the question presented. Can the government impose two convictions and sentences for the same conduct when Congress never clearly said it could?

Writing for a unanimous Court, Justice Jackson said no. Her opinion is careful but still unmistakably firm. The Court held that Congress did not clearly authorize multiple convictions under § 924(c) and § 924(j) for a single act, and that when such clarity is absent, constitutional protections against double punishment control. As Justice Jackson explains, ambiguity in criminal statutes cannot be used to justify stacking convictions that dramatically increase punishment. 

I mean, honestly, what stands out in the majority opinion is its reserve. Justice Jackson notes that federal criminal law already carries extraordinary power, and that courts must not assume Congress intended to multiply punishments without explicit authorization. She continues to reinforce that the Double Jeopardy Clause is not a technicality, but a safeguard against prosecutorial overreach. 

Justice Gorsuch filed a separate opinion concurring in part, and his writing adds an edge to the decision. While agreeing with the outcome, Gorsuch emphasizes the broader danger of allowing overlapping criminal statutes to silently erode constitutional protections. His concurrence underscores a returning concern in his jurisprudence, that vague or expansive criminal laws give prosecutors too much discretion, often at the expense of defendants’ rights. It signaled some skepticism towards a system that normalized excessive punishment through statutory layering. 

Although the Court reversed only part of the Second Circuit's judgment, the impact of the decision is significant. By holding that a single act can result in only one conviction under these provisions, the justices reaffirmed a core constitutional principle: punishment must be proportional, authorized, and clearly grounded in law. 

This case really showed the Court in a very disciplined state. There isn’t a dramatic rhetoric, no sweeping constitutional reinvention, just a firm refusal to allow punishment to expand beyond what Congress unmistakably approved. In a criminal justice system where sentence stacking is common, that control speaks volumes.