Wooden v. United States
Overview
Overview
The Supreme Court held 9-0 that for purposes of the Armed Career Criminal Act's sentencing enhancement, multiple offenses committed in a single criminal episode can still qualify as offenses 'committed on occasions different from one another' depending on the facts, and the term 'occasion' requires offense-specific analysis.
The Facts
Facts
William Dale Wooden was convicted in 1997 of ten burglaries of ten storage units in a single building on a single night. The government argued all ten convictions counted as separate ACCA predicate offenses committed on different occasions. The Sixth Circuit agreed; the Supreme Court reversed.
The Issue
Issue
Whether ten burglaries committed sequentially in a single building during one continuous criminal episode constitute offenses committed on 'occasions different from one another' under the Armed Career Criminal Act, triggering the 15-year mandatory minimum.
The Rules
Rule
Offenses qualify as occurring on different 'occasions' under the ACCA only when they were separated by meaningful intervening events or circumstances -- not merely sequential steps in a continuous criminal episode; courts look to whether the offenses were committed simultaneously, in the same location, and as part of a single criminal scheme.
The Application
Analysis
The rule requires courts to examine whether offenses were separated by meaningful intervening events or circumstances, not merely whether they were numerically distinct. Here, Wooden's ten burglaries all occurred in the same building during a single continuous criminal episode on one night, with no intervening events, changes in location, or gaps in purpose separating them. Applying this analysis, the Court found that the sequential execution of burglaries within a unified criminal scheme, all committed in temporal and spatial proximity, constituted a single occasion rather than ten distinct occasions. Because the offenses did not qualify as committed on "occasions different from one another," the ACCA enhancement did not apply.
The Conclusion
Conclusion
Unanimous ruling for Wooden. Kagan wrote the majority. The ten storage unit burglaries occurred on a single occasion; ACCA's sentencing enhancement did not apply.
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