__ U.S. __ (2016), 15-6092, Mathis v. United States
|Citation:||__ U.S. __, 136 S.Ct. 2243, 195 L.Ed.2d 604, 84 U.S.L.W. 4512, 26 Fla.L.Weekly Fed. S 315|
|Opinion Judge:||KAGAN, JUSTICE.|
|Party Name:||RICHARD MATHIS, PETITIONER v. UNITED STATES|
|Attorney:||Mark C. Fleming argued the cause for petitioner. Nicole A. Saharsky argued the cause for respondent.|
|Judge Panel:||KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C.J., and KENNEDY, THOMAS, and SOTOMAYOR, JJ., joined. KENNEDY, J., and THOMAS, J., filed concurring opinions. BREYER, J., filed a dissenting opinion, in which GINSBURG, J., joined. ALITO, J., filed a dissenting opinion. KENNEDY, JU...|
|Case Date:||June 23, 2016|
|Court:||United States Supreme Court|
The Armed Career Criminal Act (ACCA) imposes a 15-year mandatory minimum sentence on a defendant convicted of being a felon in possession of a firearm who has three prior convictions “for a violent felony,” including “burglary, arson, or extortion,” 18 U.S.C. 924(e). To determine whether a prior conviction is a listed crime, courts apply the “categorical approach,” asking whether the elements of the offense sufficiently match the elements of the generic (commonly... (see full summary)
[136 S.Ct. 2244] Argued April 26, 2016.
DECISION BELOW: 786 F.3d 1068
LOWER COURT CASE NUMBER: 14-2396
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT
786 F.3d 1068, reversed.
[136 S.Ct. 2245] [195 L.Ed.2d 607] The Armed Career Criminal Act (ACCA) imposes a 15-year mandatory minimum sentence on a defendant convicted of being a felon in possession of a firearm who also has three prior state or federal convictions " for a violent felony," including " burglary, arson, or extortion." 18 U.S.C. § § 924(e)(1), (e)(2)(B)(ii). To determine whether a prior conviction is for one of those listed crimes, courts apply the " categorical approach" --they ask whether the elements of the offense forming the basis for the conviction sufficiently match the elements of the generic (or commonly understood) version of the enumerated crime. See Taylor v. United States, 495 U.S. 575, 600-601, 110 S.Ct. 2143, 109 L.Ed.2d 607. " Elements" are the constituent parts of a crime's legal definition, which must be proved beyond a reasonable doubt to sustain a conviction; they are distinct from " facts," which are mere real-world things--extraneous to the crime's legal requirements and thus ignored by the categorical approach.
When a statute defines only a single crime with a single set of elements, application of the categorical approach is straightforward. But when a statute defines multiple crimes by listing multiple, alternative elements, the elements-matching required by the categorical approach is more difficult. To decide whether a conviction under such a statute is for a listed ACCA offense, a sentencing court must discern which of the alternative elements was integral to the defendant's conviction. That determination is made possible by the " modified [195 L.Ed.2d 608] categorical approach," which permits a court to look at a limited class of documents from the record of a prior conviction to determine what crime, with what elements, a defendant was convicted of before comparing that crime's elements to [136 S.Ct. 2246] those of the generic offense. See, e.g., Shepard v. United States, 544 U.S. 13, 26, 125 S.Ct. 1254, 161 L.Ed.2d 205. This case involves a different type of alternatively worded statute--one that defines only one crime, with one set of elements, but which lists alternative factual means by which a defendant can satisfy those elements.
Here, petitioner Richard Mathis pleaded guilty to being a felon in possession of a firearm. Because of his five prior Iowa burglary convictions, the Government requested an ACCA sentence enhancement. Under the generic offense, burglary requires unlawful entry into a " building or other structure." Taylor, 495 U.S. at 598, 110 S.Ct. 2143, 109 L.Ed.2d 607. The Iowa statute, however, reaches " any building, structure, [or] land, water, or air vehicle." Iowa Code § 702.12. Under Iowa law, that list of places does not set out alternative elements, but rather alternative means of fulfilling a single locational element.
The District Court applied the modified categorical approach, found that Mathis had burgled structures, and imposed an enhanced sentence. The Eighth Circuit affirmed. Acknowledging that the Iowa statute swept more broadly than the generic statute, the court determined that, even if " structures" and " vehicles" were not separate elements but alternative means of fulfilling a single element, a sentencing court could still invoke the modified categorical approach. Because the record showed that Mathis had burgled structures, the court held, the District Court's treatment of Mathis's prior convictions as ACCA predicates was proper.
Held : Because the elements of Iowa's burglary law are broader than those of generic burglary, Mathis's prior convictions cannot give rise to ACCA's sentence enhancement. Pp. 7-19.
(a) This case is resolved by this Court's precedents, which have repeatedly held, and in no uncertain terms, that a state crime cannot qualify as an ACCA predicate if its elements are broader than those of a listed generic offense. See, e.g., Taylor, 495 U.S. at 602, 110 S.Ct. 2143, 109 L.Ed.2d 607. The " underlying brute facts or means" by which the defendant commits his crime, Richardson v. United States, 526 U.S. 813, 817, 119 S.Ct. 1707, 143 L.Ed.2d 985, make no difference; even if the defendant's conduct, in fact, fits within the definition of the generic offense, the mismatch of elements saves him from an ACCA sentence. ACCA requires a sentencing judge to look only to " the elements of the [offense], not to the facts of [the] defendant's conduct." Taylor, 495 U.S. at 601, 110 S.Ct. 2143, 109 L.Ed.2d 607.
This Court's cases establish three basic reasons for adhering to an elements-only inquiry. First, ACCA's text, which asks only about a defendant's " prior convictions," indicates that Congress meant for the sentencing judge to ask only whether " the defendant had been convicted of crimes falling within certain categories," id., at 600, 110 S.Ct. 2143, 109 L.Ed.2d 607, not what he had done. [195 L.Ed.2d 609] Second, construing ACCA to allow a sentencing judge to go any further would raise serious Sixth Amendment concerns because only a jury, not a judge, may find facts that increase the maximum penalty. See Apprendi v. New Jersey, 530 U.S. 466, 490, 120 S.Ct. 2348, 147 L.Ed.2d 435. And third, an elements-focus avoids unfairness to defendants, who otherwise might be sentenced based on statements of " non-elemental fact[s]" that are prone to error because their proof is unnecessary to a conviction. Descamps v. United States, 570 U.S. ___, ___, 133 S.Ct. 2276, 186 L.Ed.2d 438, 457.
Those reasons remain as strong as ever when a statute, like Iowa's burglary statute, lists alternative means of fulfilling one (or more) of a crime's elements. [136 S.Ct. 2247] ACCA's term " convictions" still supports an elements-based inquiry. The Sixth Amendment problems associated with a court's exploration of means rather than elements do not abate in the face of a statute like Iowa's: Alternative factual scenarios remain just that, and thus off-limits to sentencing judges. Finally, a statute's listing of disjunctive means does nothing to mitigate the possible unfairness of basing an increased penalty on something not legally necessary to a prior conviction. Accordingly, whether means are listed in a statute or not, ACCA does not care about them; rather, its focus, as always, remains on a crime's elements. Pp. 7-16.
(b) The first task for a court faced with an alternatively phrased statute is thus to determine whether the listed items are elements or means. That threshold inquiry is easy here, where a State Supreme Court ruling answers the question. A state statute on its face could also resolve the issue. And if state law fails to provide clear answers, the record of a prior conviction itself might prove useful to determining whether the listed items are elements of the offense. If such record materials do not speak plainly, a sentencing judge will be unable to satisfy " Taylor 's demand for certainty." Shepard, 544 U.S. at 21, 125 S.Ct. 1254, 161 L.Ed.2d 205. But between the record and state law, that kind of indeterminacy should prove more the exception than the rule. Pp. 16-18.
786 F.3d 1068, reversed.
Mark C. Fleming argued the cause for petitioner.
Nicole A. Saharsky argued the cause for respondent.
KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C.J., and KENNEDY, THOMAS, and SOTOMAYOR, JJ., joined. KENNEDY, J., and THOMAS, J., filed concurring opinions. BREYER, J., filed a dissenting opinion, in which GINSBURG, J., joined. ALITO, J., filed a dissenting opinion.
The Armed Career Criminal Act (ACCA or Act), 18 U.S.C. § 924(e), imposes a 15-year mandatory minimum sentence on certain federal defendants who have three prior convictions for a " violent felony," including " burglary, arson, or extortion." To determine whether a past conviction is for one of those offenses, courts compare the elements of the crime of conviction with the elements of the " generic" version of the listed offense-- i.e., the offense as commonly understood. For more than 25 years, [195 L.Ed.2d 610] our decisions have held that the prior crime qualifies as an ACCA predicate if, but only if, its elements are the same as, or narrower than, those of the generic offense. The question in this case is [136 S.Ct. 2248] whether ACCA makes an exception to that rule when a defendant is convicted under a statute that lists...
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