United States v. Stitt, 139 S. Ct. 399

Two defendants (Stitt and Sims) convicted under 18 U.S.C. §922(g)(1) for unlawful firearm possession faced a 15‑year mandatory minimum under the Armed Career Criminal Act (ACCA), 18 U.S.C. §924(e), because of prior state burglary convictions.
ACCA’s definition of violent felony lists “burglary” as a triggering offense; the question was whether burglary of structures or vehicles "designed or adapted for overnight accommodation" falls within the statute’s generic meaning of "burglary."
Stitt’s prior Tennessee convictions involved burglary of a “habitation,” which the statute defines to include mobile homes, trailers, tents, and certain occupied vehicles.
Sims’s Arkansas statute criminalized burglary of a “residential occupiable structure,” defined to include vehicles where any person lives or that are customarily used for overnight accommodation.
District courts applied the ACCA enhancement; the Sixth and Eighth Circuits disagreed and vacated/ remanded. The Government sought certiorari to resolve circuit conflict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ACCA’s term “burglary” includes burglary of structures or vehicles adapted or customarily used for overnight accommodation	Gov: Yes — Taylor’s generic burglary includes buildings/structures adapted for overnight lodging, and many states’ statutes in 1986 so provided	Stitt/Sims: No — such mobile/nonpermanent places are outside generic burglary; some statutory language is broader than Taylor’s definition	Yes. The Court held such places fall within ACCA’s generic burglary definition under Taylor
Whether a state statute that also reaches atypical vehicles or edge cases (e.g., a car where a homeless person occasionally sleeps) disqualifies the conviction	Gov: Inclusion of adapted/customary overnight lodging does not make the statute broader than generic burglary	Sims: Arkansas wording (“in which any person lives”) might sweep ordinary vehicles used occasionally for sleeping, making it broader than generic burglary	Mixed: Court remanded Sims to let lower courts decide under state‑law construction whether the Arkansas provision was presented and whether it reaches such edge cases

Taylor v. United States, 495 U.S. 575 (defining ACCA’s generic burglary as unlawful entry or remaining in a building or other structure with intent to commit a crime)
Mathis v. United States, 579 U.S. _ (2016) (categorical approach: a statute that sweeps more broadly than generic offense does not qualify)
Begay v. United States, 553 U.S. 137 (categorical approach requires looking to statutory elements, not actual conduct)
Johnson v. United States, 576 U.S. _ (2015) (invalidating ACCA residual clause as unconstitutionally vague)
James v. United States, 550 U.S. 192 (burglary creates possibility of violent confrontation; supports ACCA’s treatment of burglary as dangerous)