Quarles v. United States, 139 S. Ct. 1872

Petitioner Jamar Quarles was arrested after a 911 call; police found a semiautomatic pistol and he pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
The government sought an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior convictions including a 2002 Michigan third-degree home-invasion conviction.
Taylor v. United States defines the ACCA generic term "burglary" as "unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a crime." 495 U.S. 575 (1990).
The legal dispute concerned the timing of the mens rea for "remaining-in" burglary: whether intent must exist at the precise moment unlawful remaining begins, or may form at any time during the continuous period of unlawful remaining.
The District Court and Sixth Circuit treated Michigan’s third-degree home-invasion statute as corresponding to generic burglary and imposed an ACCA enhancement; the Supreme Court granted certiorari due to a circuit split on the timing issue.

Issue	Quarles' Argument	Government's Argument	Held
Whether "remaining-in" burglary requires intent at the exact moment unlawful remaining begins	Quarles: intent must exist at the precise moment the defendant first unlawfully remains	Government: intent may be formed at any time while unlawfully remaining; "remaining" is a continuous act	Court: intent may be formed at any time during the continuous period of unlawful remaining; held for Government
Whether Michigan's third-degree home-invasion statute is broader than the ACCA generic burglary definition	Quarles: Michigan law sweeps more broadly because it allows intent formed at any time while present	Government: Michigan statute substantially corresponds to Taylor’s generic burglary	Court: Michigan statute substantially corresponds and thus qualifies as an ACCA predicate

Taylor v. United States, 495 U.S. 575 (1990) (establishes ACCA generic definition of burglary as unlawful entry or remaining with intent to commit a crime)
United States v. Cores, 356 U.S. 405 (1958) (interprets "remains" as continuous presence)
Descamps v. United States, 570 U.S. 254 (2013) (discusses categorical approach to predicate offenses)
Shepard v. United States, 544 U.S. 13 (2005) (limits judicial factfinding about conviction elements for enhancements)
James v. United States, 550 U.S. 192 (2007) (addresses scope of generic offense definitions under ACCA)
Ovalles v. United States, 905 F.3d 1231 (11th Cir. 2018) (advocates jury determination alternative to categorical approach)
United States v. Stitt, 139 S. Ct. 399 (2018) (discusses burglary’s danger rationale under ACCA)