Quarles v. United States (U.S. Supreme Court, June 2019)
Firearm Offenses/ACCA – A conviction for third-degree home invasion under Michigan state law is a “violent felony” under the Armed Career Criminal Act’s enumerated-offenses clause
The Supreme Court unanimously held that the defendant’s 2002 Michigan conviction for third-degree home invasion was a “violent felony” under the Armed Career Criminal Act’s enumerated-offenses clause, as the Michigan offense “substantially corresponded to” or was narrower than generic burglary under the categorical approach from Taylor v. United States.
Justice Thomas concurred, suggesting that the Court abandon the categorical approach all together.
On certiorari to the Sixth Circuit
Unanimous Opinion by Kavanaugh
Concurring Opinion by Thomas