Wooden v. United States

142 S. Ct. 1063 (2022)

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Nature of the Case

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Facts

Wooden (D) burglarized ten units in a single storage facility. The burglars proceeded from unit to unit within the facility, “crushing the interior drywall” between them. Prosecutors charged them with ten counts of burglary-though, as state law prescribes, in a single indictment. He later pleaded guilty, for that night’s work, to ten counts of burglary-one for each storage unit he had entered. Two decades later, the courts below concluded that those convictions were enough to subject D to enhanced criminal penalties under the Armed Career Criminal Act (ACCA). The ACCA mandates a 15-year minimum sentence for unlawful gun possession when the offender has three or more prior convictions for violent felonies like burglary “committed on occasions different from one another.” In 2014, D responded to a police officer’s knock on his door. The officer asked to speak with D’s wife. The officer asked if he could step inside, to stay warm. D agreed. The officer immediately spotted several guns. The officer placed D under arrest. A jury later convicted him of being a felon in possession of a firearm, in violation of 18 U. S. C. §922(g). The Probation Office recommended a sentence of 21 to 27 months. The District Court’s sentencing hearing focused on D’s ten convictions for breaking into the storage facility. D claimed they did not trigger ACCA because he burglarized the ten storage units on a single occasion, rather than “on occasions different from one another.” §924(e)(1). Based on the ACCA enhancement, the court sentenced D to 188 months (almost 16 years) in prison for unlawfully possessing a gun. The Court of Appeals affirmed. The court concluded D qualified as a career offender under ACCA. D appealed.