Richard Mathis v. United States

If, for purposes of determining penalty under the Armed Career Criminal Act, the court finds that a defendant was previously convicted under a statute with alternative means of satisfying one element of a crime, then the court shall determine whether the elements of the prior conviction, and not the facts of the records except for limited circumstances, sufficiently match the elements of the Act’s generic crimes

Petitioner pleaded guilty to being a felon in the possession of a firearm. Respondent sought penalty under the Armed Career Criminal Act (the "Act"), which imposes a 15-year mandatory minimum sentence on defendants who have been convicted of committing a felony while possessing a firearm following three prior convictions for violent felonies. Under the Act, violent felony includes: burglary, arson, or extortion. The Act provides this list of crimes only in their generic versions. To determine whether a prior conviction fits into one of the listed generic crimes, courts look at whether the elements of the crime sufficiently match the elements of the generic crime. Courts pay no attention to the facts of the case. If a statute lists multiple alternatives for elements, then courts look to limited records to determine what elements defendant was convicted under and then compare that to a generic offense. Petitioner was previously convicted five times under the Iowa burglary statute, which is broader than the generic burglary statute because it provides alternate ways of satisfying a locational element. The district court inspected records of Petitioner’s prior convictions to determine the location of the burglary and the Eight Circuit approved of this method. The Supreme Court held that the sentencing courts had no right to explore the facts of an offense and abandon longstanding principles of interpretation under the Act. The Court reasoned that the Act’s text favors an elements-only approach and exploring the facts would raise Sixth Amendment concerns and would be unfair to defendants. When encountering alternative statutes like Iowa’s, the Court recommends first determining whether the listed items are elements or means and then resorting to the record only for the purpose of determining elements of the offense. REVERSED.