Mathis v. United States
136 S. Ct. 2243
| SCOTUS | 2016Background
- Mathis pleaded guilty to being a felon in possession of a firearm; at sentencing the Government sought ACCA's 15-year mandatory minimum based on five prior Iowa burglary convictions.
- ACCA enhances sentences for defendants with three prior convictions for a "violent felony," which includes "burglary" as defined by the ordinary or "generic" meaning (unlawful entry of a building/structure with intent to commit a crime).
- The categorical approach compares the elements of the prior-state offense to the elements of the generic federal offense; only if the state offense's elements are the same as or narrower than the generic offense may it count as a predicate.
- Iowa's burglary statute enumerates various locations ("building, structure, land, water, or air vehicle") as alternative ways to satisfy a single locational element; Iowa courts treat those listed locations as alternative means, not separate elements.
- The Eighth Circuit applied the modified categorical approach to the records of Mathis's prior convictions, found the convictions involved structures (not vehicles), and affirmed the ACCA enhancement.
- The Supreme Court reversed, holding that when a statute lists alternative factual means (not alternative elements), ACCA requires an elements-only inquiry; courts may not use the modified categorical approach to pick among means.
Issues
| Issue | Mathis's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether ACCA allows sentencing courts to treat statutory alternative means as distinct elements and examine records to see which means supported a prior conviction. | Courts must compare only formal elements; if the statute's elements are broader than generic burglary, the prior conviction cannot count. | When a statute lists alternatives (even as means), a court may use the modified categorical approach to identify which alternative in fact occurred and count it if it matches generic burglary. | If a statute's listed items are mere means rather than elements, ACCA forbids using the modified categorical approach to determine which means occurred; courts must compare the state statute's elements to the generic offense. |
| Whether the modified categorical approach may be used to identify non-elemental facts (means) in prior convictions for ACCA purposes. | The modified approach is limited to identifying which alternative elements were necessarily found; it cannot be used to ascertain means. | The modified approach can be applied regardless of whether the statutory alternatives are labeled means or elements, because the practical result should be the same. | The modified categorical approach may be used only to identify which element (when a statute is divisible into multiple elements) the conviction necessarily established; it cannot be used to probe non-elemental factual means. |
| How to determine whether statutory alternatives are "elements" or "means." | Follow state-law authoritative sources (state supreme court rulings, statute text); if state law says they are means, federal courts must treat them as such and not look to records for means. | Practical reliance on charging papers/records is appropriate to determine what the prior conviction factually involved and thus whether it matches generic burglary. | Federal courts should look first to authoritative state-law sources; if unresolved, limited review of conviction records may be used only to decide whether the statutory alternatives are elements (not to discover which means occurred). |
Key Cases Cited
- Taylor v. United States, 495 U.S. 575 (1990) (establishes the categorical approach: compare elements of the state offense to generic federal offense)
- Shepard v. United States, 544 U.S. 13 (2005) (limits the record materials courts may consult under the modified categorical approach)
- Descamps v. United States, 570 U.S. 254 (2013) (clarifies that the modified categorical approach applies only when a statute lists alternative elements creating multiple crimes)
- Richardson v. United States, 526 U.S. 813 (1999) (distinguishes elements from "brute facts" and explains jury unanimity implications)
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts that increase penalty beyond statutory maximum must be found by a jury, with limited exception for prior convictions)
- James v. United States, 550 U.S. 192 (2007) (reiterates elements-focused inquiry for ACCA predicates)