United States v. Stitt
The Supreme Court ruled that burglarizing a structure or vehicle adapted for overnight living — like a mobile home, RV, or camping tent — counts as "burglary" for purposes of a federal law that requires a 15-year minimum sentence for repeat violent offenders caught with a gun.
The unanimous decision resolves disagreement among federal appeals courts over how broadly to read the word "burglary" in the Armed Career Criminal Act, keeping the mandatory sentencing enhancement available for people with prior convictions for breaking into mobile or non-permanent living spaces.
“An offender who breaks into a mobile home, an RV, a camping tent, a vehicle, or another structure that is adapted for or customarily used for lodging runs a similar or greater risk of violent confrontation.”
Explains why burglarizing mobile or non-permanent living spaces poses the same danger as classic burglary.
How it got here: District courts applied the sentencing enhancement in both cases; the Sixth and Eighth Circuits disagreed, vacated the sentences, and the government asked the Supreme Court to review.
The Case in Depth
What happened
Two men, Victor Stitt and Jason Sims, were each convicted in federal court of illegally possessing a firearm. Because each had prior state burglary convictions, judges added a mandatory 15-year minimum sentence under the Armed Career Criminal Act. Stitt's prior conviction was under a Tennessee law covering burglary of mobile homes and vehicles set up for overnight stays; Sims's was under a similar Arkansas law.
The question before the Court
Does burglary of a mobile home, camper, or vehicle set up for overnight living count as "burglary" under the law that adds extra prison time for repeat violent offenders?
Why it matters
People convicted of illegally possessing a firearm who have past burglary convictions involving mobile homes, campers, or similar living spaces will remain subject to the 15-year mandatory minimum sentence under the Armed Career Criminal Act. The ruling also gives federal courts nationwide a single, consistent answer to a question that had split the circuits.
What changes now
Stitt's sentence enhancement is reinstated because the Sixth Circuit's ruling is reversed. Sims's case goes back to the lower courts, which must still decide a separate argument about whether Arkansas's law also covers ordinary cars where someone merely sleeps sometimes, a question the Supreme Court left open. This is a final decision on the legal question, though further proceedings remain in Sims's case.
What this does not decide
The Court did not decide whether Arkansas's burglary law is too broad because it might also cover an ordinary car where a homeless person occasionally sleeps; that separate argument, which depends partly on state law, was left for the lower courts to consider on remand.
How the Court got there
The legal reasoning, step by step
- The Court applied the categorical approach first set out in Taylor v. United States, which requires judges to compare the elements of a prior state crime to a generic legal definition, rather than looking at what the individual defendant actually did.
- Taylor defined generic burglary as unlawfully entering or remaining in a building or other structure with intent to commit a crime, and the Court treated that definition as controlling here.
- The Court found that when the Armed Career Criminal Act was passed in 1986, most states already defined burglary to include vehicles adapted or customarily used for overnight lodging, showing this fits the term's ordinary meaning at the time.
- The Court reasoned that breaking into a mobile home, RV, or camping tent creates the same kind of danger of a violent confrontation with an occupant that concerned Congress when it singled out burglary as a violent felony.
- The Court rejected the argument that only full-time living spaces should count, finding no sign that Congress meant to draw a line between part-time and full-time lodging.
- The Court distinguished its own earlier decisions in Taylor and Mathis, explaining that those cases involved statutes covering ordinary vehicles like boats or cars used for storage, not vehicles specifically adapted for overnight living, so they did not resolve this particular question.
Doctrinal impact
Cases affected by this decision
Reaffirms Taylor v. United States (495 U. S. 575)
The Court relied on Taylor's generic definition of burglary as still controlling and applied it to mobile living spaces.
Distinguishes Mathis v. United States
The Court said Mathis involved ordinary vehicles used for storage, not overnight lodging, so it didn't decide this question.