State Offenses Broader Than Federal Statute Prevent Sentencing Enhancement

State statutes that provide multiple elements and alternatives for a single crime cannot trigger a sentencing enhancement under the Armed Career Criminals Act

Mathis v. United States, U.S., No. 15-6092, 6/23/16.

   A defendant convicted for burglary under a state statute that included a broader definition than which is found under the Armed Career Criminals Act (ACCA). The federal statute defined burglary as “an unlawful entry into a building or other structure,” while the Iowan statute’s definition of burglary encompassed more, including unlawful entry into any “building, structure, [or] land, water, or air vehicle.”

   In response, the court said, “For more than 25 years, 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,” Justice Elena Kagan wrote for the 5-3 majority. “The question in this case is whether ACCA makes an exception to that rule when a defendant is convicted under a statute that lists multiple, alternative means of satisfying one (or more) of its elements. We decline to find such an exception.”

http://www.supremecourt.gov/opinions/15pdf/15-6092_1an2.pdf