Law School Case Brief
Mathis v. United States - 136 S. Ct. 2243 (2016)
Under the Armed Career Criminal Act, the U.S. Supreme Court has approved the modified categorical approach for use with statutes having multiple alternative elements. Under that approach, a sentencing court looks to a limited class of documents (for example, the indictment, jury instructions, or plea agreement and colloquy) to determine what crime, with what elements, a defendant was convicted of. The court can then compare that crime, as the categorical approach commands, with the relevant generic offense.
The Armed Career Criminal Act (ACCA), imposed a 15-year mandatory minimum sentence on certain federal defendants who had three prior convictions for a “violent felony,” including “burglary, arson, or extortion.” To determine whether a past conviction is for one of those offenses, courts compared the elements of the crime of conviction with the elements of the “generic” version of the listed offense—i.e., the offense as commonly understood. For more than 25 years, the prior crime qualified as an ACCA predicate if its elements were the same as those of the generic offense.
Mathis pleaded guilty to being a felon in possession of a firearm. Because of his five prior Iowa burglary convictions, the Government requested an ACCA sentence enhancement. Under the generic offense, burglary required unlawful entry into a “building or other structure.” The Iowa statute, however, included “any building, structure, [or] land, water, or air vehicle.” Under Iowa law, the list of places does not set out alternative elements, but rather alternative means of fulfilling a single locational element.
The District Court applied the modified categorical approach, found that Mathis had burgled structures, and imposed an enhanced sentence. The Eighth Circuit affirmed. Acknowledging that the Iowa statute swept more broadly than the generic statute, the court determined that, even if “structures” and “vehicles” were not separate elements but alternative means of fulfilling a single element, a sentencing court could still invoke the modified categorical approach.
Were Mathis’ burglary convictions predicate crimes under the ACCA?
The Court held that Mathis was improperly sentenced under the ACCA based on prior convictions for burglary since the elements of burglary under state law included unlawful entry into a building, structure, or land, water, or air vehicle, the alternate means of committing burglary depending on what was entered were broader than the elements of generic burglary which only included entry into a structure or building, and thus the defendant's burglary convictions were not predicate crimes under the ACCA.
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