United States v. Christopher Stowell, 82 F.4th 607

Christopher Stowell pleaded guilty to being a felon in possession of a firearm; the district court applied the ACCA sentencing enhancement and imposed a 180-month sentence.
The Presentence Report (PSR) listed three prior qualifying convictions: a 2004 burglary and two 2006 battery convictions.
Charging documents and the PSR showed the two batteries involved different victims and occurred on different days (on or about March 8 and March 11, 2006).
Stowell argued the 2006 batteries were the same occasion because he was arrested and convicted on the same dates for both, and alternatively argued the Sixth Amendment required a jury to decide the different-occasions issue.
The en banc Eighth Circuit affirmed: it held the multi-day gap and different victims support treating the batteries as committed on different occasions, and any Sixth Amendment error was harmless beyond a reasonable doubt.
A dissent argued Wooden requires a fact-intensive, admissible-evidence inquiry (and possibly a jury determination), and that remand for the district court was appropriate because the PSR was relied on without a developed record.

Issue	Stowell's Argument	Government's Argument	Held
Whether the two 2006 battery convictions were "committed on occasions different from one another" under the ACCA	The batteries were part of the same occasion because arrests/convictions occurred on the same dates; the close timing and related conduct could make them one episode	The batteries occurred days apart and involved different victims, so they are separate occasions	Affirmed: two batteries separated by several days and different victims are different occasions
Whether the Sixth Amendment requires a jury, rather than a judge, to find that prior convictions occurred on different occasions	Wooden’s multi-factor test creates factual questions that must be decided by a jury under Alleyne/Apprendi principles	Even if the Sixth Amendment issue arises, any error was harmless beyond a reasonable doubt because no reasonable juror could find the offenses were the same occasion	Court avoided deciding the constitutional question on the merits; held any Sixth Amendment error (if present) was harmless

Wooden v. United States, 142 S. Ct. 1063 (Supreme Court guidance on assessing whether prior convictions occurred on different occasions under the ACCA)
Alleyne v. United States, 570 U.S. 99 (fact increasing penalty is an element for jury determination)
Apprendi v. New Jersey, 530 U.S. 466 (principle that sentencing facts increasing penalty are elements)
Neder v. United States, 527 U.S. 1 (standard for harmlessness beyond a reasonable doubt for omitted elements)
Brecht v. Abrahamson, 507 U.S. 619 (harmless-error standard for federal cases)
Chapman v. California, 386 U.S. 18 (constitutional harmless-error standard)
United States v. Humphrey, 759 F.3d 909 (8th Cir. standard of review for ACCA different-occasions determinations)
United States v. Red Elk, 426 F.3d 948 (8th Cir. on harmlessness review of Sixth Amendment sentencing errors)
United States v. Pepper, 747 F.3d 520 (8th Cir. holding that failing to dispute PSR facts amounts to admission)