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

Click here to read the opinion.


Tom Church

Tom is a trial and appellate lawyer focusing on criminal defense and civil trials. Tom is the author of "The Federal Docket" and is a contributor to Mercer Law Review's Annual Survey in the areas of federal sentencing guidelines and criminal law. Tom graduated with honors from the University of Georgia Law School where he served as a research assistant to the faculty in the areas of constitutional law and civil rights litigation. Read Tom's reviews on AVVO. Follow Tom on Linkedin.

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