Supreme Court clarifies criteria for using state convictions to impose enhanced federal sentences

Supreme Court clarifies criteria for using state convictions to impose enhanced federal sentences

The US Supreme Court [official website] ruled [opinion, PDF] 5-3 Thursday in Mathis v. United States [SCOTUSblog materials] that a prior crime can be used for imposing enhanced federal sentences in a new conviction under the Armed Career Criminal Act [materials] (ACCA), “but only if its elements are the same as, or narrower than, those of the generic offense.” The court also held that there is no exception to this rule “when a defendant is convicted under a statute that lists multiple, alternative means of satisfying one (or more) of its elements.” In other words, the court stated that courts must ask “whether the crime of conviction is the same as, or narrower than, the relevant generic offense” and not whether the defendant’s “means of committing the crime falls within the generic definition.” This particular case involved the Iowa burglary statute under which Richard Mathis was convicted as a felon being in possession of a firearm. The statute in question covered a broader range of conduct than that covered by generic burglary and set out alternative ways of satisfying the locational elements of the crime. Nevertheless, a federal district court imposed an ACCA sentence enhancement, and the US Court of Appeals for the Eight Circuit affirmed. In the absence of an enhanced federal sentence, a defendant convicted for being in possession of a firearm following three prior convictions for a violent felony gets a 10-year maximum penalty. However, with the ACCA’s enhanced sentence, there is a 15-year mandatory minimum sentence. The prior convictions for the said violent felony can be under either federal or state statutes. Recognizing that the court has repeatedly made clear for more than 25 years that application of ACCA involves, “and involves only, comparing elements,” the Supreme Court reversed the Eighth Circuit’s decision in an opinion by Justice Elena Kagan.

Justices Clarence Thomas and Anthony Kennedy wrote a concurring opinion, while Justices Steven Breyer and Samuel Alito dissented. This opinion is part of a series of decisions being decided by the Supreme Court as it nears the last day of its current term. Also Thursday the Supreme Court ruled in Birchfield v. North Dakota [opinion, PDF] that governments can require drunk drivers to undergo breath tests without first obtaining a warrant, but cannot require them to take a more invasive blood test. Many other groundbreaking decisions have been released by the Supreme Court in the last week including another Fourth Amendment case, Utah v. Strieff, that included a scathing dissent from Justice Sonia Sotomayor and a decision on a race-conscious college admissions program at the University of Texas [JURIST reports]. More opinions are expected to be released on Monday.