Wooden v. United States. (U.S. Supreme Court, March 2022)

The Federal Docket

March 10, 2022

The Supreme Court issued a significant opinion regarding the applicability of the Armed Career Criminal Act (“ACCA”) to a defendant with multiple convictions that arise from a single criminal episode. William Dale Wooden was sentenced to a mandatory minimum of 15 years in prison under the ACCA based on the district court finding that he had several prior convictions for a “violent felony” based on his prior convictions for burglary. Wooden had committed 10 burglaries that were charged as separate counts in an indictment, and he pleaded guilty to all of the counts. The Supreme Court reversed the district court, holding that Wooden’s prior convictions counted as only one prior conviction for the purposes of the ACCA since the burglaries arose out of “a single criminal episode in 1997,” when Wooden broke into a storage facility and then stole items from 10 separate storage units. These successive burglaries occurred on “one occasion” and thus could not be counted as separate convictions. The Court directed lower courts to apply a multi-factor balancing test to determine if a defendant’s prior convictions are for offenses that occurred on different occasions.

Justice Gorsuch concurred, critiquing the majority’s multi-factor balancing test and emphasizing the importance of the rule of lenity. His concurrence includes a lengthy discussion of the rule, its origins, and its significance.

Justice Sotomayor concurred, agreeing with Justice Gorsuch that “the rule of lenity provides an independent basis for ruling in favor of a defendant” in a case where the application of the ACCA is ambiguous.

Justice Kavanaugh concurred, writing to emphasis the “very limited role” the rule of lenity plays in criminal case law. Instead, Justice Kavanaugh argued the court should “vigorously apply (and where appropriate, extend) mens rea requirements” when a law does not provide fair notice.

Justice Barrett concurred to write about the legislative history of the ACCA’s amendments regarding a defendant’s offense on particular “occasions.”

Certiorari to the Sixth Circuit
Opinion by Kagan, joined by Roberts, Breyer, Sotomayor, and Kavanaugh, and Thomas, Alito, and Barrtt in part
Concurring opinions by Sotomayor, Kavanaugh, Barrett, and Gorsuch

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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