Wooden v. United States
The Supreme Court ruled unanimously that ten burglary convictions stemming from one night at a single storage facility count as only one prior conviction under the federal law that mandates a 15-year minimum sentence for gun offenders with a violent criminal history.
The decision narrows the reach of the Armed Career Criminal Act by making clear that a crime spree at one location in one continuous episode cannot multiply into dozens of separate 'occasions' — protecting people whose multiple convictions grew out of a single incident from automatic classification as career offenders.
How it got here: The federal district court applied the ACCA enhancement and sentenced Wooden to nearly 16 years; the Sixth Circuit affirmed; Wooden asked the Supreme Court to step in to resolve a split among the federal appeals courts, and the Court agreed to hear the case.
The Case in Depth
What happened
In 1997, William Dale Wooden and associates broke into a Georgia storage facility and moved from unit to unit — knocking through walls — stealing from ten different units in a single night. Georgia prosecutors charged him with ten counts of burglary (in one indictment, as state law required) and he pleaded guilty to all. About seventeen years later, Wooden was convicted of illegally possessing a firearm as a felon. The government sought a 15-year mandatory minimum under the Armed Career Criminal Act, arguing the ten burglary convictions each counted as a separate prior violent-felony conviction from a different "occasion."
The question before the Court
Do multiple burglary convictions from a single night at one storage facility count as separate criminal "occasions" that trigger a 15-year mandatory minimum federal sentence?
The Court's answer
No — the Court ruled that Wooden's ten burglary convictions from one night at one storage facility count as only one prior conviction for purposes of the Armed Career Criminal Act's (ACCA's) 15-year mandatory minimum. ACCA imposes that enhanced sentence only when an offender has three or more prior violent felony convictions from occasions "different from one another," and the Court held that all ten of Wooden's crimes took place on a single occasion.
The Court defined "occasion" by its ordinary meaning — an event or episode — which can include multiple sequential acts. Because Wooden's burglaries occurred on the same night, at the same building, in one uninterrupted sequence, all part of the same scheme, they formed one occasion. The Government's approach — treating each crime as its own occasion the moment its legal elements were satisfied — would have collapsed ACCA's two separate requirements (three convictions and three separate occasions) into one, leaving the "occasions" requirement no independent work to do.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Defendants facing federal gun-possession charges who have multiple prior convictions from a single criminal episode cannot be automatically subjected to ACCA's 15-year mandatory minimum. Prosecutors must now show that prior offenses arose from genuinely separate occasions — not just that they were technically sequential — before seeking the enhancement, and sentencing courts must weigh the circumstances of each prior crime.
What changes now
The Sixth Circuit's judgment is reversed and the case is sent back to the lower courts for resentencing without the ACCA enhancement. Because Wooden's ten burglary convictions count as only one prior conviction, he does not qualify for the 15-year mandatory minimum, and his nearly 16-year sentence will be recalculated under the lower statutory ceiling. Future courts applying ACCA must use the multi-factor test — weighing timing, location, and the relationship among offenses — to assess whether prior crimes occurred on different occasions.
What this does not decide
The Court explicitly declined to address whether the Sixth Amendment requires a jury — rather than a judge — to decide whether prior crimes occurred on a single occasion, because Wooden did not raise that argument. The Court also did not establish a bright-line rule for every hard case; the multi-factor test will be applied to future disputes one at a time.
Concurrences and dissents
Concurrence — Justice Sotomayor
Justice Sotomayor joined the Court's opinion in full and wrote separately to make two points. First, Justice Gorsuch's doubts about the factual record in Wooden's case only underscore that the Government failed to carry its burden of proving the sentencing enhancement applies. Second, she agreed with Justice Gorsuch that the rule of lenity — the principle that ambiguous criminal laws should be read in the defendant's favor — provides an independent basis for ruling for defendants in closer cases, and she joined the portions of his opinion developing that argument.
Concurrence — Justice Kavanaugh
Justice Kavanaugh joined the Court's opinion in full and wrote separately to push back on Justice Gorsuch's call for a broader rule of lenity. In his view, lenity applies only after courts have exhausted every tool of statutory interpretation and still face a 'grievous' ambiguity — a bar that is rarely met because careful analysis almost always yields a best answer. He argued that fair-notice concerns in criminal law are better addressed by the presumption that crimes require criminal intent (mens rea), not by expanding the rule of lenity.
Concurrence in part — Justice Barrett
Justice Barrett, joined by Justice Thomas, agreed with the outcome and joined all but Part II-B of the majority opinion. She accepted the Court's ordinary-meaning analysis of the word 'occasion' but objected to the majority's reliance on the legislative history surrounding the Petty case. In her view, the Court improperly elevated the Solicitor General's decades-old brief confessing error in Petty into a near-governing interpretive standard, which goes beyond what can fairly be attributed to Congress. She would rest the result solely on the statutory text.
Concurrence — Justice Gorsuch
Justice Gorsuch, joined by Justice Sotomayor as to Parts II-IV, agreed Wooden should win but rejected the majority's multi-factor balancing test as providing too little guidance. He argued the test will produce inconsistent results in countless future cases because the factors are non-exhaustive, often incommensurable, and come with no instructions for resolving conflicts among them. The right rule of decision, in his view, is the rule of lenity: when a criminal statute is genuinely ambiguous, the doubt must be resolved in favor of liberty — not resolved by judicial guesswork about purposes and factors.
How the Court got there
The legal reasoning, step by step
- The Court began with the ordinary meaning of 'occasion' in ACCA's text — a word that commonly means an event or episode. The Court noted that such an episode may include multiple sequential activities: a wedding encompasses a ceremony, cocktail hour, dinner, and dancing, all part of one occasion even though they don't happen at once. The same logic applies to crime.
- The Government argued that each offense produces its own 'occasion' at the precise moment its legal elements are satisfied — so Wooden's sequential entries into ten storage units were ten separate occasions. The Court rejected this as hyper-technical: it would make someone a career offender 'in the space of a minute' by treating each punch in a barroom brawl, or each room entered in a single burglary spree, as a distinct occasion.
- The Government's elements-based test would largely collapse ACCA's two separate filters — requiring three convictions AND those convictions from different occasions — into one. Because most violent crimes (burglary, assault) are physically impossible to commit simultaneously, almost any offender with three separate convictions would automatically satisfy the 'occasions' requirement under the Government's reading, stripping it of independent force.
- Instead, the Court held that whether crimes occurred on one or different occasions requires a multi-factor inquiry looking at timing (were the crimes close in time and uninterrupted?), location (were they at the same place?), and the character and relationship of the offenses (did they share a common scheme or purpose?). In most cases this will be straightforward; a single factor — especially time or place — will often be decisive.
- Applying these factors to Wooden's case, every consideration pointed to a single occasion: the crimes occurred on the same night, at the same one-building facility, in an uninterrupted sequence, each burglary facilitating the next, all driven by the same motive and means. Georgia law itself required all ten charges in a single indictment because they arose from 'the same conduct.'
- The statute's history confirmed this reading. Congress added the 'occasions' clause in 1988 specifically to prevent ACCA from applying to people like Samuel Petty, who had received the 15-year enhancement based on multiple robbery counts from a single restaurant holdup. The Solicitor General had confessed error in Petty's case, arguing ACCA should not reach multiple convictions from 'a single criminal episode,' and Congress amended the law to require separate occasions — showing it meant the enhancement for true repeat offenders, not those committing multiple acts in one spree.