Wooden v. United States

Background

In 1997 William Wooden and others broke into a one-building storage facility and stole from ten different storage units. State prosecutors charged him with ten burglary counts in a single indictment and he pleaded guilty. Years later, after a 2014 arrest for being a felon with a gun, Wooden was convicted under the federal gun-possession law and faced a 15-year minimum sentence under the Armed Career Criminal Act if his ten prior burglaries counted as crimes "committed on occasions different from one another."

Reasoning

The Court asked whether closely related crimes that occur one after another in a single episode count as separate occasions. It rejected a narrow rule that each time element is satisfied creates a new occasion. Instead, courts should consider timing, location, and the character and relationship of the offenses to decide if the acts form one episode. Applying that approach, the Court found the ten burglaries were a single occasion because they happened the same night, at the same facility, in an uninterrupted course of conduct, and were charged together. The Court also noted that Congress added the occasions language to prevent single episodes from producing career-criminal status. The Sixth Circuit’s ruling was reversed.

Real world impact

The decision limits the use of ACCA’s 15-year minimum when multiple convictions arise from one criminal episode in one place. People with clustered offenses at a single site or on a single night may avoid enhanced mandatory minimums. The case goes back to the lower court for resentencing consistent with this ruling.

Dissents or concurrances

Several Justices wrote separately: some stressed resolving reasonable doubts in defendants’ favor (the rule of lenity), one highlighted mens-rea concerns, and another disputed reliance on the Solicitor General’s earlier brief.