Wooden v. United States
595 U.S. 360
| SCOTUS | 2022Background
- In 1997 Wooden and accomplices broke into a one‑building storage facility and stole from ten separate storage units; Georgia charged all ten burglaries in a single indictment and Wooden pleaded guilty to ten counts.
- The state sentences ran concurrently; decades later Wooden was convicted of being a felon in possession of a firearm (18 U.S.C. §922(g)).
- The Government sought an Armed Career Criminal Act (ACCA) enhancement (§924(e)(1)), which imposes a 15‑year minimum if the defendant has three prior convictions for enumerated felonies “committed on occasions different from one another.”
- The District Court and Sixth Circuit held each separate unit entry was a distinct “occasion” because the burglaries were sequential (not simultaneous), triggering ACCA and producing a much longer federal sentence.
- The Supreme Court reversed: it held Wooden’s ten burglaries arising from a single uninterrupted episode at one location counted as a single “occasion” under ACCA.
Issues
| Issue | Plaintiff's Argument (Wooden) | Defendant's Argument (United States) | Held |
|---|---|---|---|
| Whether multiple burglaries in one continuous episode count as multiple “occasions” under ACCA | Wooden: the ten burglaries were part of one criminal episode at one location and therefore one occasion | Govt: an “occasion” is the moment an offense’s elements are satisfied; sequential offenses occur at different times so each is a different occasion | Held: convictions from a single criminal episode (as here) count as one occasion — ACCA enhancement does not apply multiple times |
| Proper interpretive test for “occasions different from one another” | Wooden: use ordinary meaning and a multi‑factor, holistic inquiry (time, place, character/relationship of offenses) | Govt: use an elements‑based, temporal‑distinctness test — each completed offense is a separate occasion | Held: adopt ordinary‑meaning, multi‑factor approach (timing matters but not in split‑second elements sense; location and relatedness also relevant) |
| Role of statutory history and purpose (including Petty and Congress’s amendment) | Wooden: history confirms ACCA targets true career/revolving‑door offenders; Congress added the occasions clause to limit reach | Govt: disputes relevance or reads history to allow sequential acts to be separate occasions | Held: legislative history (Solicitor General confession in Petty and subsequent amendment) and ACCA’s purpose support treating closely related acts in one episode as a single occasion |
Key Cases Cited
- United States v. Petty, 798 F.2d 1157 (8th Cir. 1986) (Eighth Circuit decision that prompted Solicitor General confession)
- United States v. Petty, 828 F.2d 2 (8th Cir. 1987) (on remand for further consideration after confession of error)
- United States v. Bryant, 579 U.S. 140 (2016) (uses “on one occasion” language to cover multiple discrete acts)
- Begay v. United States, 553 U.S. 137 (2008) (discusses ACCA’s purpose targeting armed career criminals)
- Taylor v. United States, 495 U.S. 575 (1990) (background on ACCA and its focus on serious repeat offenders)
- United States v. Rideout, 3 F.3d 32 (2d Cir. 1993) (example of treating offenses a day or more apart as separate occasions)