United States v. Stitt

Background

Two men were convicted of unlawfully possessing a firearm and faced a possible mandatory 15-year sentence because each had prior state burglary convictions. One had Tennessee convictions for burglary of a “habitation” including mobile homes and tents. The other had Arkansas convictions covering “residential occupiable structures,” including vehicles customarily used for overnight accommodation. Lower courts reached different conclusions about whether those prior convictions counted under the federal sentencing law, and the Government asked the Court to resolve the question.

Reasoning

The Court used the long-standing approach that asks whether a state crime matches the generic definition of burglary: unlawful entry into a building or other structure with intent to commit a crime. The Justices concluded that Congress intended a uniform, common-sense definition that covers structures and vehicles adapted or customarily used for overnight lodging. The opinion noted that many States treated such vehicles and structures as burglary targets by 1986 and that breaking into them poses risks similar to breaking into a house, so those state convictions fall within the federal definition. The Court reversed the Sixth Circuit on the Tennessee-related case.

Real world impact

The ruling means prior burglaries of mobile homes, RVs, tents, and similar vehicles can count toward the federal 15-year enhancement for certain gun offenders. The Court vacated the Eighth Circuit’s judgment and remanded the Arkansas case so lower courts can consider a specific argument about whether an occasional place where a homeless person sleeps qualifies under state law. This part of the result is not yet final for that defendant.