Supreme Court sides with defendant in Armed Career Criminal Act case

The Supreme Court on Monday ruled in favor of a criminal defendant the justices found had been handed an overly harsh sentence based on lower courts’ mistaken application of a law. 

The crux of the case turned on how many criminal “occasions” occurred one night in 1997 when William Dale Wooden and three others entered a single-building storage facility in Georgia, smashed through the drywall separating different storage areas within and stole from a total of 10 units.

The number of criminal “occasions” is critical because the Armed Career Criminal Act (ACCA) slaps a mandatory 15-year minimum sentence on illegal gun possession for offenders with a record of three or more violent felony convictions committed “on occasions different from one another.”

Years later, when Wooden was charged with an unrelated gun possession offense, the lower courts determined Wooden’s 1997 burglary counted as 10 separate criminal occasions, with each storage unit Wooden entered being treated separately under the ACCA’s “occasions clause.” 

Wooden was handed a nearly 16-year sentence for unlawful gun possession, largely as a result of the ACCA’s 15-year mandatory minimum sentence enhancement.

But in Monday’s unanimous judgment, the Supreme Court said Wooden’s 1997 burglary occurred in “a single criminal occasion,” not 10. In effect, the court ruled, the ACCA should not have applied to Wooden’s illegal gun possession charge. 

“Here, every relevant consideration shows that Wooden burglarized ten storage units on a single occasion, even though his criminal activity resulted in double-digit convictions,” Justice Elena Kagan wrote for the majority. 

“Wooden committed his burglaries on a single night, in a single uninterrupted course of conduct. The crimes all took place at one location, a one-building storage facility with one address. Each offense was essentially identical, and all were intertwined with the others,” Kagan continued. “The burglaries were part and parcel of the same scheme, actuated by the same motive, and accomplished by the same means. Indeed, each burglary in some sense facilitated the next, as Wooden moved from unit to unit to unit, all in a row.” 

The justices were unanimous in their judgment, but separate concurring opinions were issued by Justices Sonia Sotomayor and Brett Kavanaugh, as well as Amy Coney Barrett, joined by Clarence Thomas, and Neil Gorsuch, joined by Sotomayor.