Descamps v. United States
Headline: Court limits sentence enhancements under federal career-offender law, blocks using plea or trial facts to count convictions under indivisible state statutes like California burglary, making some ACCA enhancements harder to obtain.
Holding:
- Stops courts from treating convictions under indivisible, overbroad state statutes as ACCA burglaries.
- May reduce mandatory 15-year ACCA enhancements for some defendants with California §459 burglaries.
- Resolves a circuit split and changes how sentencing judges use plea and indictment records.
Summary
Background
A federal defendant, Matthew Descamps, was convicted of being a felon in possession of a firearm. The Government sought a long mandatory sentence under the Armed Career Criminal Act (ACCA) based on three prior convictions, including a California burglary under Penal Code §459. That law punishes a person who “enters” certain places with intent to steal or commit a felony and does not require unlawful entry as in the common “generic” burglary definition. Descamps argued his §459 conviction could not count as an ACCA burglary; the District Court and Ninth Circuit examined his plea colloquy and other records and disagreed.
Reasoning
The Court said judges must decide ACCA questions by comparing the elements of the prior statute to the elements of the generic crime, not by probing the old case’s facts. It held the “modified categorical approach,” which permits limited review of indictments, jury instructions, and plea colloquies, applies only when a state statute is divisible and lists alternative elements. If a statute is indivisible and simply broader than the generic offense, a sentencing court may not consult those records to treat the earlier conviction as generic burglary. Applying that rule, the Court found §459 indivisible and reversed Descamps’ enhanced sentence.
Real world impact
The ruling prevents many sentencing courts from using plea or trial records to qualify convictions under ACCA when the state statute is indivisible and overbroad. That means some defendants who admitted facts that match the generic crime will not automatically receive ACCA enhancements. The opinion resolves a split among federal circuits about how to treat statutes like §459 and will affect future federal sentencing decisions.
Dissents or concurrances
Justice Kennedy joined the Court’s judgment but warned of strains on State statutes and suggested Congress consider clearer rules. Justice Thomas agreed with the outcome but not the Court’s reasoning. Justice Alito dissented, arguing Descamps’ plea transcript showed he necessarily admitted generic burglary.
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