Wooden v. United States
Headline: Court limits career‑offender enhancement, holds multiple burglaries in one storage facility count as one prior offense under ACCA, reducing sentence exposure for similar defendants.
Holding: In a single sentence, the Court decided that ten burglaries from one uninterrupted episode at one storage facility count as one prior conviction under ACCA, so the statute’s 15‑year enhancement did not apply.
- Limits ACCA’s 15‑year enhancement for single‑episode multiple convictions.
- Requires judges to weigh time, place, and relationship of offenses.
- May reduce sentences for similar single‑episode offenders.
Summary
Background
A man, William Wooden, was convicted of being a felon in possession of a firearm after police found guns in his home. Decades earlier he had pleaded guilty to ten burglary counts for entering and stealing from ten storage units in a single night and building. At sentencing on the gun charge, prosecutors sought a 15‑year minimum under the Armed Career Criminal Act (ACCA) based on those ten prior burglaries, and the District Court and Sixth Circuit agreed.
Reasoning
The Court addressed whether the ten burglaries happened on ‘‘occasions different from one another.’’ It explained that an ordinary meaning of “occasion” can cover a series of related acts that form one episode. The Court adopted a multi‑factor approach—looking at timing, location, and the offenses’ character and relationship—and examined ACCA’s history. Congress added the occasions clause after a contested appeal (Petty) so the law would not treat all sequential acts as separate career‑forming occasions. Applying these points, the Court concluded Wooden’s serial entries at one storage facility in one uninterrupted course of conduct were one occasion.
Real world impact
The Court reversed the Sixth Circuit, held Wooden’s ten burglaries count as a single prior conviction under ACCA, and remanded for further proceedings. The decision directs judges to weigh time, place, and the relationship among offenses when applying ACCA’s ‘‘occasions’’ requirement rather than treating every sequential act as a new occasion.
Dissents or concurrances
Several Justices wrote separately: Justice Sotomayor agreed with the outcome; Justice Gorsuch (joined in parts by Justice Sotomayor) emphasized applying the rule of lenity when doubt exists; Justice Kavanaugh discussed mens‑rea protections and limited lenity; Justice Barrett objected to relying on legislative history about the Solicitor General’s prior brief.
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