US Supreme Court finds breaking into multiple storage units equals one crime for sentencing enhancement purposes News
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US Supreme Court finds breaking into multiple storage units equals one crime for sentencing enhancement purposes

A fractured US Supreme Court ruled Monday in Wooden v. United States that a man who broke into 10 separate storage units committed only one crime for sentencing enhancement purposes under the Armed Career Criminal Act (ACCA).

James Wooden broke into a mini-storage facility in 1997 and burglarized 10 different storage units, for which he pleaded guilty to 10 acts of burglary. In 2015, he was arrested for being a felon in possession of a firearm. The government charged him under the ACCA, which would subject Wooden to a 15-year mandatory minimum sentence, but only if he had three prior violent felonies. The government claimed the 10 burglary charges qualify as 10 violent felonies, while Wooden argued that all 10 burglaries occurred on the same “occasion” and so count as only one violent felony for the ACCA. Because there was a split between the circuits regarding what an “occasion” means, the court agreed to hear the case.

In Monday’s ruling, the court held, “Convictions arising from a single criminal episode, in the way Wooden’s did, can count only once under ACCA.” Justice Elena Kagan delivered the court’s opinion, in which Chief Justice John Roberts and Justices Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh joined. Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett joined all of the opinion except Part II-B, which states, “Statutory history and purpose confirm our view of the occasions clause’s meaning, as well as our conclusion that Wooden is not a career offender.”

While all the justices agreed with Kagan’s conclusion, there were several concurring opinions filed. Sotomayor and Kavanaugh each filed concurring opinions. Coney Barrett filed an opinion concurring in part and concurring in the judgment, in which Thomas joined, and Gorsuch filed an opinion concurring in the judgment, in which Sotomayor joined as to Parts II, III and IV.