Wooden v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: March 7, 2022
  • Case #: 20–5279
  • Judge(s)/Court Below: KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and BREYER, SOTOMAYOR, and KAVANAUGH, JJ., joined, and in which THOMAS, ALITO, and BARRETT, JJ., joined as to all but Part II–B. SOTOMAYOR, J., filed a concurring opinion. KAVANAUGH, J., filed a concurring opinion. BARRETT, J., filed an opinion concurring in part and concurring in the judgment, in which THOMAS, J., joined. GORSUCH, J., filed an opinion concurring in the judgment, in which SOTOMAYOR, J., joined as to Parts II, III, and IV.
  • Full Text Opinion

Convictions stemming from a single criminal episode count as a single “occasion” under 18 U.S.C. §924(e)(1).

Petitioner burglarized ten storage units on the same night, one after the other, and was charged and pleaded guilty to ten counts of burglary in a single indictment.  Petitioner was later arrested for being a felon in possession of a firearm under 18 U.S.C. §922(g).  Respondent decided to pursue an enhanced penalty under the Armed Career Criminal Act (ACCA), which applies when a §922(g) offender has three previous convictions for violent felonies, and the three felonies were committed on “occasions different from one another.”  18 U.S.C. §924(e)(1).  The District Court and the Court of Appeals for the Sixth Circuit held that the ten burglaries were ten different occasions.  On appeal, the Supreme Court of the United States reversed, holding that convictions resulting from a single criminal episode count as a single “occasion” under §924(e)(1).  The Supreme Court reasoned that considering each breach of a storage unit as a separate occasion went against the ordinary use of the word “occasion.”  Further, the Supreme Court considered the history of the “occasion” clause and found that it was added to prevent courts from applying ACCA to multiple counts developing from a single episode.  Petty v. United States, 481 U. S. 1034, 1034–1035 (1987).  Therefore, Petitioner’s “ten burglary convictions were for offenses committed on a single occasion.”  REVERSED and REMANDED.

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