Justices Clear Up Career-Criminal Sentencing

     (CN) — A divided Supreme Court ruled Thursday that sentencing enhancements under the Armed Career Criminal Act depend on whether elements of prior state convictions are the same as elements of equivalent, generic offenses.
     Police arrested Iowa resident Richard Mathis in 2013, after 15-year-old male said Mathis forcibly molested him. Despite the allegations that got Mathis arrested, federal prosecutors indicted him on a single count of being a felon in possession of a firearm – to which he pleaded guilty in 2014.
     A federal judge sentenced Mathis to 15 years in prison under the Armed Career Criminal Act, or ACCA, finding that his five second-degree burglary convictions were violent felonies under the act.
     The Eighth Circuit upheld Mathis’ sentence in 2015, finding that while Iowa’s burglary laws are broader than federal law, two of his burglary convictions involved entering garages – which matched with the federal definition of “generic burglary” under the ACCA.
     A third conviction – for interference with official acts inflicting serious injury – satisfied the requirement of three violent felonies under the act and justified the 15-year sentence, according to the Eighth Circuit.
     Mathis asked the U.S. Supreme Court to resolve a circuit split as to whether courts can look at a defendant’s underlying conduct from a conviction to determine whether a federal crime has been committed without considering the various forms of committing the offense as defined by state law. The high court agreed in January to review the case.
     On Thursday, the Supreme Court reversed the Eighth Circuit, ruling 5-3 that Mathis’ sentence was improperly enhanced under the ACCA because the elements of Iowa’s burglary law are broader than elements of generic burglary.
     “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 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.” (Parentheses in original.)
     Kagan said the high court’s precedents “make this a straightforward case.”
     Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas and Sonia Sotomayor joined Kagan in the majority opinion.
     Justice Stephen Breyer, however, wrote a dissenting opinion, in which Justice Ruth Bader Ginsburg joined.
     Breyer said he thinks the majority’s opinion could “unnecessarily complicate federal sentencing law, often preventing courts from properly applying the sentencing statute that Congress enacted.”
     “The majority’s approach, I fear, is not practical. Per­haps the statutes of a few states say whether words like ‘boat’ or ‘building’ stand for an element of a crime or a means to commit a crime. I do not know,” Breyer wrote. “I do know, however, that many states have burglary statutes that look very much like the Iowa statute before us today.”
     Justice Samuel Alito also dissented from the majority, in a separate opinion.
     “A real-world approach would avoid the mess that today’s decision will produce. Allow a sentencing court to take a look at the record in the earlier case to see if the place that was burglarized was a building or something else,” Alito wrote. “If the record is lost or inconclusive, the court could refuse to count the conviction. But where it is perfectly clear that a building was burglarized, count the conviction.”

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