Wooden v. United States
The Supreme Court unanimously ruled that a man who broke into ten storage units during a single night committed crimes on only one criminal 'occasion,' shielding him from the Armed Career Criminal Act's 15-year mandatory minimum — more than a decade longer than what was initially recommended.
The decision resolves a longstanding split among lower courts over how to count prior convictions under the Act, establishing a multi-factor test focused on the timing, location, and interconnected nature of the crimes rather than whether each offense happened at a technically distinct moment in time.
How it got here: A federal trial court sentenced Wooden under ACCA's 15-year mandatory minimum; the Sixth Circuit affirmed; Wooden asked the Supreme Court to step in and the Court agreed to resolve a split among the circuits.
The Case in Depth
What happened
In 1997, William Dale Wooden and three accomplices broke into a one-building storage facility in Dalton, Georgia, burrowing through interior walls to steal items from ten different storage units during a single evening. He pleaded guilty to ten counts of burglary and served concurrent sentences. About seventeen years later, Wooden was convicted of illegally possessing a firearm. Federal prosecutors argued his ten burglaries counted as ten separate prior convictions committed on distinct "occasions," triggering a mandatory 15-year minimum — nearly thirteen years more than what the government's own probation office had initially recommended.
The question before the Court
Can the government count a man's ten burglaries of a single storage facility on one night as ten separate criminal "occasions" to trigger a 15-year mandatory minimum sentence under the Armed Career Criminal Act?
The Court's answer
No — the Court ruled that crimes committed during a single criminal episode count as only one "occasion" under the Armed Career Criminal Act's occasions clause. In everyday English, an "occasion" is an event or episode that can encompass multiple sequential activities, just as a wedding's ceremony, cocktail hour, and dancing all belong to one occasion. That ordinary meaning defeats the government's argument that each burglary was its own occasion because a person can legally enter only one structure at a time.
Applied to Wooden, every relevant factor pointed to a single occasion: one night, one uninterrupted course of conduct, one building, essentially identical and intertwined offenses, each burglary enabling the next. Georgia law recognized this by requiring all ten charges in a single indictment. The Court also found that Congress added the "occasions" language to ACCA specifically to prevent cases like Wooden's — where multiple convictions from one criminal episode would otherwise trigger the harshest sentencing penalty.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People convicted of multiple crimes during a single criminal spree — burglarizing several units in one building on one night, for instance — cannot automatically be counted as multiple-strike offenders under the Armed Career Criminal Act. This limits prosecutors' ability to stack convictions from one episode to trigger mandatory 15-year sentences for illegal gun possession, and gives defense lawyers a clearer path to challenge such enhancements.
What changes now
The Sixth Circuit's judgment is reversed and the case is sent back for resentencing without the ACCA enhancement, likely resulting in a sentence well below the nearly 16 years Wooden received. Going forward, all lower courts must apply the multi-factor occasions test — weighing timing, location, and the character of the offenses — when deciding whether prior crimes count as separate ACCA predicates. Courts in circuits that had already used a similar multi-factor approach will see little change; those that had applied a strict sequential-equals-separate rule must now retool.
What this does not decide
The Court did not address whether the Sixth Amendment requires a jury — rather than a judge — to find the facts relevant to the "occasions" clause. Wooden did not raise that constitutional question, and it remains open. Justice Gorsuch's concurrence flags it as a serious issue the Court will likely need to confront soon.
Concurrences and dissents
Concurrence — Justice Sotomayor
Justice Sotomayor joined the majority opinion in full but wrote separately to emphasize that the government bore the burden of proving the sentencing enhancement applied — a burden it failed to meet on these facts. She also agreed with Justice Gorsuch that the rule of lenity, which requires ambiguous criminal laws to be read in a defendant's favor, provides an independent basis for ruling for defendants in closer cases, and she joined the portions of his concurrence making that argument.
Concurrence — Justice Kavanaugh
Justice Kavanaugh joined the majority fully but wrote to push back on Justice Gorsuch's call to expand the rule of lenity. He defended the existing rule that lenity applies only when a statute remains 'grievously ambiguous' after exhausting all interpretive tools, arguing that a looser trigger would produce inconsistency and unfairness. He suggested that the mens rea presumption — which generally requires the government to prove a defendant's guilty mental state — better addresses fair-notice concerns in federal criminal law.
Concurrence in part — Justice Barrett
Justice Barrett, joined by Justice Thomas, agreed with the Court's analysis of the word 'occasion' and the conclusion that Wooden's crimes count only once under ACCA. But she declined to join Part II-B, which relied on the legislative history surrounding the Petty case and the Solicitor General's decades-old brief. She argued the majority went too far in treating that brief as a governing interpretive guide, and would rest the decision solely on the statutory text.
Concurrence — Justice Gorsuch
Justice Gorsuch agreed the Sixth Circuit's sequential-crimes rule was wrong but criticized the majority's multi-factor balancing test as supplying too little guidance and likely perpetuating conflicting results in lower courts. He argued the rule of lenity — which requires any reasonable doubt about a penal law to be resolved in favor of the defendant — is the proper tool for close cases under the occasions clause. He offered a lengthy defense of lenity's historical roots in due process and separation of powers, and argued it should apply whenever there is 'reasonable doubt,' not only when ambiguity is 'grievous.'
How the Court got there
The legal reasoning, step by step
- The Court started with the ordinary meaning of 'occasion' — the statute's key word — which in everyday English refers to an event, occurrence, or episode. Crucially, such an episode may itself include multiple activities that happen sequentially rather than simultaneously. The Court illustrated this with a wedding: its ceremony, cocktail hour, dinner, and dancing happen at different moments yet all belong to one occasion. Criminal sprees work the same way.
- The government argued each burglary formed its own 'occasion' because a person can complete the legal elements of burglary — entering a structure with criminal intent — only in one structure at a time. The Court rejected this elements-based timing test as hyper-technical and contrary to ordinary language. It also collapsed the statute's two separate requirements: ACCA demands both three prior felony convictions and that those felonies were committed on 'occasions different from one another.' The government's rule would make the 'occasions' requirement redundant, since nearly any sequence of three qualifying crimes would automatically satisfy it.
- Instead, the Court adopted a multi-factor test that asks whether the crimes were close in time, close in location, and whether they were similar or intertwined in character and purpose. Offenses committed in an uninterrupted course of conduct at one place tend to form a single occasion; crimes separated by large gaps of time or distance tend not to. The Court emphasized that this inquiry will usually be straightforward and intuitive.
- Applied to Wooden's burglaries, every factor pointed the same direction: one night, one unbroken course of action, one building at one address, ten essentially identical offenses each facilitated by the last, all part of a single scheme. Georgia law itself recognized the connection — it required prosecutors to charge all ten counts in a single indictment because the crimes 'arose from the same conduct.'
- The statute's history confirmed this reading. Congress added the 'occasions' clause specifically after a man named Samuel Petty received ACCA's 15-year minimum for multiple robbery convictions arising from a single restaurant holdup. The Solicitor General confessed error in that case, arguing ACCA should not reach 'multiple felony convictions arising out of a single criminal episode,' and Congress promptly amended the statute. That history aligned with ACCA's core purpose — targeting the 'special danger' of the true armed career criminal, someone who repeatedly commits violent crimes as a way of life, not someone who commits a single night's string of connected crimes.