Today the Supreme Court decided Wooden v. United States, No. 20-5279 (S. Ct. March 7, 2022) soundly tossing out a sentencing enhancement for a Georgia man who was designated a “career criminal” based on his burglary convictions for breaking into a single mini-storage facility and stealing items from 10 separate storage units. Previous coverage available here and here.
Section 924(e) of the Armed Career Criminal Act required the court imposes a 15-year minimum sentence for illegal gun possession if a defendant has three or more prior convictions “committed on occasions different from one another.”
The issue was whether multiple criminal offenses committed in succession as part of a single crime spree occurred on different "occasions" for purposes of sentence enhancements under the Armed Career Criminal Act (ACCA). The Court was unanimous in concluding that a single crime spree is a single "occasion," even if it resulted in multiple convictions, but disagreed about how to get there.
“Wooden’s night of crime is a perfect case in point. His one-after-another-after-another burglary of ten units in a single storage facility occurred on one ‘occasion,’ under a natural construction of that term and consistent with the reason it became part of ACCA” the court wrote.
Courts should consider “a range of circumstances” in deciding whether crimes took place on a single occasion, the Supreme Court wrote. Among them are whether the offenses were close in time, part of an uninterrupted course of conduct and in the same place.
The government's interpretation of the law "can make someone a career offender in the space of a minute" and the high court has in the past interpreted the word 'occasion' "to encompass multiple, temporally discrete offenses."
Federal prosecutors had initially requested a 21-month sentence but later argued that Mr. Wooden was a career criminal under the ACCA, saying each burglary charge counted as an occasion. Mr. Wooden was sentenced to 15 and a half years in prison on the gun charge by the trial court — about 14 years longer than the guidelines sentence had he not been subject to the statute.