The Supreme Court ruled unanimously that a burglar’s 10 prior convictions arising from a single criminal episode don’t count as multiple convictions under a federal three-strikes sentencing law.
The often-litigated federal Armed Career Criminal Act (ACCA) of 1984 was enacted in response to concerns that a small number of repeat offenders commit a disproportionate number of offenses. The statute requires that a 15-year minimum sentence be imposed on individuals found guilty of illegally possessing a firearm who have three or more prior convictions for a violent felony such as burglary “committed on occasions different from one another.”
A violent felony is defined by the statute as one that necessarily involves “the use, attempted use, or threatened use of physical force against the person of another.”
The new ruling by the high court could affect other individuals sentenced under ACCA.
According to the U.S. Sentencing Commission, armed career criminals consistently make up a small portion—under 1 percent—of the federal criminal caseload. From fiscal 2010 to fiscal 2019, the number of armed career criminals fell by nearly half, from 590 to 312, the commission reported (pdf) in March 2021.
The court’s March 7 opinion (pdf) in Wooden v. U.S., court file 20-5279, was written by Justice Elena Kagan. The case is an appeal from the U.S. Court of Appeals for the 6th Circuit, which upheld the trial court and ruled against Wooden in December 2019.
William Dale Wooden and three accomplices arrived at a storage complex next to his home in Dalton, Georgia, in 1997 and broke through the drywall dividing storage areas within and stole from a total of 10 units, an event for which Wooden was convicted.
Felons in the United States aren’t allowed to have firearms, and years later, Wooden was convicted of felony gun possession. The trial court in the gun case found the prior burglaries counted as 10 separate criminal occasions and largely based on the ACCA, he was given a fresh nearly 16-year sentence for unlawful gun possession.
Wooden’s attorney, Allon Kedem of Arnold and Porter, welcomed the ruling.
“We’re delighted the Supreme Court agrees that Mr. Wooden is not an armed career criminal and never should have been subject to a 15-year mandatory-minimum sentence,” Kedem told The Epoch Times by email.
“We’re hopeful that he will soon be resentenced and sent back home to his family.”
The Biden administration had argued in favor of leaving the sentence intact.
But Kagan and her colleagues rejected the government’s submissions.
Kagan recounted how, in November 2014, Wooden answered a police officer’s knock on his door.
“The officer asked to speak with Wooden’s wife. And noting the chill in the air, the officer asked if he could step inside, to stay warm. Wooden agreed. But his good deed did not go unpunished. Once admitted to the house, the officer spotted several guns. Knowing that Wooden was a felon, the officer placed him under arrest.”
During the sentencing phase for the gun offense in U.S. District Court for the Eastern District of Tennessee at Knoxville, the court imposed an extra-lengthy sentence, but was wrong to do so, she wrote.
“Here, every relevant consideration shows that Wooden burglarized ten storage units on a single occasion, even though his criminal activity resulted in double-digit convictions,” Kagan wrote.
“Wooden committed his burglaries on a single night, in a single uninterrupted course of conduct. The crimes all took place at one location, a one-building storage facility with one address. Each offense was essentially identical, and all were intertwined with the others,” she wrote.
“The burglaries were part and parcel of the same scheme, actuated by the same motive, and accomplished by the same means. Indeed, each burglary in some sense facilitated the next, as Wooden moved from unit to unit to unit, all in a row.”
Although the Supreme Court’s judgment was unanimous, four justices filed separate concurring opinions. Justice Sonia Sotomayor filed a concurring opinion, as did Justices Brett Kavanaugh, Amy Coney Barrett, and Neil Gorsuch.
U.S. Solicitor General Elizabeth Prelogar, who represents the Biden administration before the Supreme Court, didn’t respond by press time to a request by The Epoch Times for comment.