Quarles v. United States
Headline: Court affirms that 'remaining in' burglary counts for enhanced federal sentences when intent forms at any time while unlawfully inside, easing treatment of some prior home-invasion convictions as violent felonies.
Holding: The Court held that for purposes of the Armed Career Criminal Act, a remaining-in burglary qualifies when the person forms intent to commit a crime at any time while unlawfully remaining inside a building, and affirmed the Sixth Circuit.
- Makes more prior home-invasion convictions count as violent felonies for enhanced federal sentences.
- Eases application of the Armed Career Criminal Act to people with remaining-in burglary convictions.
- Resolves conflicting appellate court views on when intent must form for remaining-in burglary.
Summary
Background
On August 24, 2013, police in Grand Rapids arrested Jamar Quarles after a woman said he threatened her at gunpoint and hit her. Officers found a semiautomatic pistol in Quarles’s home. Quarles pleaded guilty to being a felon in possession of a firearm. At sentencing, the Government treated three earlier convictions — including a 2002 Michigan third-degree home invasion — as burglary priors under the Armed Career Criminal Act, which raises prison terms for felons with three qualifying violent convictions.
Reasoning
The narrow question was whether "remaining-in" burglary requires the intent to commit a crime at the exact moment a person first unlawfully stays inside, or whether it is enough that the person forms that intent at any time while unlawfully remaining. The Court, relying on its 1990 Taylor decision and the ordinary meaning of "remain," held that the intent may be formed at any time during the continuous unlawful presence. The Court therefore found Michigan’s statute substantially corresponds to the federal definition and affirmed the Sixth Circuit.
Real world impact
The ruling means some prior state convictions for home invasion or remaining inside a dwelling can count as violent felonies for enhanced federal sentences. That makes it easier for federal prosecutors and judges to apply the Armed Career Criminal Act when a prior state conviction involved unlawfully staying inside and forming criminal intent while there. The decision resolves a split among appellate courts about the timing of intent for remaining-in burglary.
Dissents or concurrances
Justice Thomas joined the judgment but wrote separately to criticize the Court’s categorical approach, arguing that juries, not judges, should decide whether a past conviction matched the federal definition and that the current method raises constitutional concerns.
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