Justices Spar Over How to Interpret the Armed Career Criminal Act
Today the Supreme Court decided Wooden v. Untied States, which concerned whether multiple criminal offenses committed in succession as part of a single crime spree occurred on different “occasions” for purposes of sentence enhancements under the Armed Career Criminal Act (ACCA). The Court was unanimous in concluding that a single crime spree is a single “occasion,” even if it resulted in multiple convictions, but disagreed about how to get there.
Justice Kagan wrote for the Court, joined in full by the Chief Justice and Justices Breyer, Sotomayor, and Kavanaugh. Justices Thomas, Alito, and Barrett joined all but one section of Justice Kagan’s opinion (Part II-B) which concerned statutory purpose and history. Justices Kavanaugh and Sotomayor each wrote separate concurring opinions. Justice Barrett wrote an opinion concurring in part and concurring in the judgment, joined by Justice Thomas. And Justice Gorsuch filed an opinion concurring in the judgment, joined in part by Justice Sotomayor.
Justice Kagan briefly summarized the question presented to the Court, and its conclusion:
In the course of one evening, William Dale Wooden burglarized ten units in a single storage facility. He later pleaded guilty, for that night’s work, to ten counts of burglar —one for each storage unit he had entered. Some two decades later, the courts below concluded that those convictions were enough to subject Wooden to enhanced criminal penalties under the Armed Career Criminal Act (ACCA). That statute mandates a 15 year minimum sentence for unlawful gun possession when the offender has three or more prior convictions for violent felonies like burglary “committed on occasions different from one another.” 18 U. S. C. §924(e)(1). The question presented is whether Wooden’s prior convictions were for offenses occurring on different occasions, as the lower courts held, because the burglary of each unit happened at a distinct point in time, rather than simultaneously. The answer is no. Convictions arising from a single
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