Supreme Court Clarifies Burglary Definition Under the Armed Career Criminal Act

The Armed Career Criminal Act (ACCA) was designed to require harsher sentences for convicted felons who use a gun in the commission of a crime. It was passed during the Reagan Administration as a deterrent against violent crime. Defendants must have three or more prior convictions on their record in order to fall within a category of felons who must receive a minimum sentence of 15 years if they are convicted again of using a gun in a crime. It has engendered plenty of controversy because criminal defense advocates see the law as too draconian in that it deprives the court of opportunities to evaluate the individual circumstances of a case before sentencing defendants to long terms in prison.

In United States v. Stitt, the Supreme Court just issued a unanimous decision that clarifies how burglary offenses will be treated under the ACCA. Even if a state law definition of burglary is more expansive than the generic understanding of the term, it will still count in terms of including prior convictions in a defendant’s sentencing review. In this case, the defendant argued that the applicable state court definition of burglary for one of his prior convictions included the invasion of a vehicle that had been turned into a living structure. He pointed out that the generic definition of burglary did not include a vehicle at all. The Supreme Court overruled the Sixth Circuit Court of Appeals and held that the state court definition of burglary was allowed to stand for the purpose of imposing a sentence under the ACCA. Therefore, the defendant should receive at least 15 years for his conviction of threatening to kill someone with a gun pointed in her face.

What makes this case particularly noteworthy is that it signals that the ACCA is not going anywhere soon. While there has been plenty of talk of criminal justice reform in the news lately, the Supreme Court unanimously closed the door for plenty of future appeals from defendants with state law convictions on their record and facing sentencing under the ACCA. The fact that the decision was unanimous also indicates that the justices may be trying to project a unified image to their approach when possible. Following the controversy surrounding the confirmation of the most recently appointed justice, this show of unanimity could help squash rampant rumors that the Supreme Court is more divided now than ever before.

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