Wooden v. United States
The Supreme Court ruled unanimously that Wooden's ten burglary convictions from a single night in one storage facility counted as only one prior 'occasion' under the Armed Career Criminal Act, sparing him from a mandatory 15-year minimum sentence.
The decision clarifies that the Act's harsh sentencing enhancement targets true repeat offenders with distinct criminal episodes — not someone whose multiple convictions all arose from one continuous crime spree.
How it got here: The federal district court applied the ACCA enhancement and sentenced Wooden to nearly 16 years; the Sixth Circuit affirmed; the Supreme Court granted review to resolve a circuit split over the meaning of "occasions different from one another."
The Case in Depth
What happened
In 1997, William Wooden and accomplices broke into a one-building storage facility in Georgia and moved from unit to unit, stealing from ten different spaces in a single uninterrupted night. Georgia charged him with ten counts of burglary — one per unit — in a single indictment, as state law required. Years later, after Wooden was convicted of illegally possessing a firearm, federal prosecutors argued those ten old burglary convictions each represented a separate prior "occasion," triggering a mandatory 15-year federal sentencing enhancement.
The question before the Court
Did William Wooden's ten burglary convictions — all from one continuous night inside a single storage facility — count as separate criminal "occasions" that triggered a mandatory 15-year minimum sentence under federal law?
The Court's answer
No — the ten burglaries arose from a single criminal episode and count as only one prior "occasion" under the Armed Career Criminal Act. The word "occasion" in everyday language means an event or episode, and such an episode can include multiple sequential acts without each one becoming its own separate occasion. The Court rejected the government's argument that every crime forms its own "occasion" the moment its legal elements are completed, because that rule would effectively erase the Act's "different occasions" requirement — since almost no crimes can physically happen at the exact same instant.
The right approach, the Court held, is a multi-factor inquiry weighing the timing of the crimes, how close together they took place, and how closely the offenses were connected. In Wooden's case, every factor pointed to one occasion: a single night, a single building, an uninterrupted sequence of identical crimes sharing the same motive and method, each one leading directly to the next — precisely the kind of case Congress meant to exclude from the Act's career-criminal label.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People convicted of multiple crimes during a single uninterrupted criminal episode will not automatically face the Armed Career Criminal Act's 15-year mandatory minimum just because each offense technically completed at a different moment. Courts must weigh timing, location, and how closely related the crimes were — a ruling that could reduce sentences for defendants whose prior records are dominated by spree-style offenses.
What changes now
The Sixth Circuit's ruling is reversed, and Wooden's case goes back to the lower courts for resentencing without the ACCA enhancement. Without the enhancement, his maximum sentence for illegal gun possession is ten years rather than a 15-year mandatory minimum. The decision does not resolve a related constitutional question — whether a jury rather than a judge must determine whether prior crimes occurred on separate occasions — because Wooden did not raise that issue.
What this does not decide
The Court did not decide whether a jury (rather than a judge) must determine whether prior convictions occurred on separate occasions; Wooden did not raise that constitutional question. The decision also does not supply a precise formula for every hard case under the "occasions" clause — it prescribes a multi-factor standard that will require further case-by-case development.
Concurrences and dissents
Concurrence — Justice Sotomayor
Justice Sotomayor joined the full majority opinion but wrote separately to stress that Justice Gorsuch's concern about ambiguous cases underscored only the government's failure to carry its burden of proving the sentencing enhancement applied. She agreed with Gorsuch that the rule of lenity — the principle that ambiguous criminal laws should be read in the defendant's favor — provides an independent reason to rule for defendants in closer cases, and she joined Parts II through IV of his concurrence in the judgment.
Concurrence — Justice Kavanaugh
Justice Kavanaugh joined the majority opinion in full but wrote separately to push back on Justice Gorsuch's call for a broader rule of lenity. He argued that the rule of lenity should apply only when a statute remains 'grievously' ambiguous after exhausting every tool of statutory interpretation — meaning it should rarely if ever be decisive. He contended that the better safeguard for fair notice in criminal law is the deeply rooted presumption that the government must prove a defendant's criminal intent (mens rea), not a loosened lenity standard.
Concurrence in part — Justice Barrett
Justice Barrett, joined by Justice Thomas, agreed with the majority's ordinary-meaning analysis of 'occasion' and with the result. But she declined to join Part II-B, which relied on the legislative history of the Petty case and the Solicitor General's old confession of error as interpretive guides. She argued those sources were too indirect and unreliable to count as authoritative expressions of what Congress intended, and that the statute's text alone was sufficient to reach the same conclusion.
Concurrence — Justice Gorsuch
Justice Gorsuch agreed the Sixth Circuit's sequential-crimes rule was wrong but would not have adopted the majority's multi-factor test, which he argued would generate unpredictable, inconsistent results across lower courts given the endless variety of factual patterns. Instead, he argued the case — and many future ACCA occasions-clause cases — should be decided by the rule of lenity: when reasonable people can disagree about whether crimes formed one occasion or many, the ambiguity must always resolve in the defendant's favor. His opinion provides an extended historical and constitutional defense of the rule of lenity, tracing it to due process and separation-of-powers principles. Justice Sotomayor joined Parts II through IV.
How the Court got there
The legal reasoning, step by step
- The Court began by rejecting the Sixth Circuit's rule that crimes occurring at distinct points in time — sequentially rather than simultaneously — always happen on separate 'occasions.' The ordinary meaning of 'occasion' is an event or episode, and everyday speech groups a series of closely connected, non-simultaneous activities into a single occasion, much as a wedding ceremony, cocktail hour, dinner, and dancing are all part of one event.
- The government argued that an 'occasion' ends the moment a crime's legal elements are satisfied, so each sequential crime automatically forms its own occasion. The Court said this approach would largely swallow the Armed Career Criminal Act's (ACCA) two separate requirements — three prior violent felony convictions AND three separate occasions — because most crimes physically cannot occur at the exact same instant. Treating every sequential crime as a new occasion would give the 'different occasions' requirement almost no independent work to do.
- The Court held that the proper standard is a multi-factor inquiry asking whether the crimes formed a single criminal episode. Relevant considerations include proximity in time (closely timed, uninterrupted conduct tends to be one occasion), proximity in location (crimes farther apart are more likely to be separate occasions), and the character and relationship of the offenses (similar, intertwined crimes sharing a common scheme or purpose are more apt to form one occasion). The Court emphasized this will be straightforward and intuitive in most cases.
- Applying that standard to Wooden's facts, every factor pointed to a single occasion: the burglaries occurred on one night, in one continuous course of conduct, at one address, using the same method, for the same purpose — with each burglary facilitating the next as Wooden broke through walls between units. Georgia law itself reflected this by requiring all ten counts in one indictment because they 'ar[ose] from the same conduct.'
- ACCA's legislative history confirmed the result. Congress added the 'occasions' clause in 1988 specifically after the Solicitor General confessed error in United States v. Petty — a case where someone received the ACCA enhancement based on multiple robbery convictions from a single restaurant hold-up. Congress amended the statute to ensure the enhancement applied only to true 'career criminals' with repeated criminal episodes over time, not to someone whose multiple convictions trace to one night's spree.