Mathis v. United States

Whether it is appropriate to use the modified categorical approach of defining a crime to include a burglary conviction within the Armed Career Criminal Act.

Petitioner was convicted as a felon in possession of a firearm and received a sentence in accordance with the Armed Career Criminal Act (ACCA), which applies to individuals who have had three prior violent felony convictions. Under the ACCA, Petitioner had special conditions placed upon him in the form of supervised release.

The district court sentenced Petitioner to the statutory minimum of fifteen years as provided by the ACCA by including Petitioner's prior burglary convictions as violent felonies. The Eighth Circuit found “occupied structure” had an alternative meaning and used the “modified categorical approach” to fit the generic burglary under the ACCA to affirm Petitioner’s conviction.

Petitioner argues that Iowa statute defines burglary as entry of an “occupied structure” instead of the generic “building or automobile” is too broadly sweeping, which ends the ACCA inquiry.