Law School Case Brief
Taylor v. United States - 495 U.S. 575, 110 S. Ct. 2143 (1990)
The only plausible interpretation of 18 U.S.C.S. § 924(e)(2)(B)(ii) is that, like the rest of the enhancement statute, it generally requires the trial court to look only to the fact of conviction and the statutory definition of the prior offense. This categorical approach, however, may permit the sentencing court to go beyond the mere fact of conviction in a narrow range of cases where a jury was actually required to find all the elements of generic burglary. For example, in a state whose burglary statutes include entry of an automobile as well as a building, if the indictment or information and jury instructions show that the defendant was charged only with a burglary of a building, and that the jury necessarily had to find an entry of a building to convict, then the government should be allowed to use the conviction for enhancement.
Under § 1402 of the Anti-Drug Abuse Act of 1986, 18 U.S.C.S. § 924(e), an accused who was convicted, under 18 U.S.C.S. § 922(g), of unlawful possession of a firearm was subject to a sentence enhancement if the accused has three prior convictions for a violent felony. The term "violent felony" was defined, under § 924(e), as any crime punishable by imprisonment for a term exceeding one year that: (i) has as an element the use of physical force against another person, or (ii) was a "burglary" or other specified offense "or otherwise involves conduct that presents a serious potential risk of physical injury to another." However, the term "burglary" was not defined under § 924(e). Defendant, who had four prior convictions, including two for second-degree burglary under Missouri law, pleaded guilty in the United States District Court for the Eastern District of Missouri to violating § 922(g), but conditioned his guilty plea on the right to appeal an enhanced sentence, based on his contention that his burglary convictions should not count for enhancement purposes because they did not involve conduct that presented a serious potential risk of physical injury to another. The District Court imposed an enhanced sentence under § 924(e). Ruling that, although the word "burglary" in § 924(e) meant "burglary," state law defines the term; thus, the United States Court of Appeals for the Eighth Circuit affirmed the judgment of the District Court. The United States Supreme Court granted defendant's petition for certiorari review.
Did the word “burglary” in 18 U.S.C.S. § 924(e) mean “burglary” however the state has choosen to define it?
The United States Supreme Court held that an offense constituted "burglary" for purposes of § 924(e) if the offense's statutory definition substantially corresponded to "generic" burglary--any crime having the basic elements of unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a crime--or the charging paper and jury instructions actually required the jury to find all the elements of generic burglary in order to convict the accused, because the term "burglary" in § 924(e) had to have some uniform definition independent of the labels employed by the various states' criminal codes. Moreover, the Court held that there was no specific indication that Congress meant to incorporate into 924(e) the common-law meaning of burglary--the breaking and entering of a dwelling at night with intent to commit a felony, and Congress did not mean to include as predicate offenses under 924(e) only a subclass of burglaries whose elements included conduct that presented a serious risk of physical injury to another, over and above the risk inherent in ordinary burglaries. According to the Court, § 924(e) generally required the trial court to look to only the fact of the prior convictions and the statutory definitions of the convictions, and not to the facts underlying the convictions. Based on the foregoing, the Court held that a remand for further proceedings was necessary because it was not apparent from the record before the court whether the burglary statutes under which defendant had been convicted included all the elements of generic burglary.
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