In one evening, William Dale Wooden of Georgia burglarized ten units in a single storage facility. He pleaded guilty to ten counts of burglary, one for each storage unit he had entered. Two decades later, the courts below concluded that those convictions were enough to subject Wooden to enhanced criminal penalties under the Armed Career Criminal Act (ACCA). That statute mandates a 15-year minimum sentence for unlawful gun possession when the offender has three or more prior convictions for violent felonies like burglary “committed on occasions different from one another.”
The Supreme Court considered whether Wooden’s prior convictions were for offenses occurring on different occasions, as lower courts held, because the burglary of each unit happened at a distinct point in time, rather than simultaneously. The answer is no, wrote Justice Elena Kagan in an opinion released on Monday. Convictions arising from a single criminal episode, in the way Wooden’s did, can count only once under ACCA. The high court reversed a lower court opinion upholding Wooden's sentence of nearly 16 years in prison, much higher than he would have received absent the armed career criminal law. The ruling's effect on Wooden was not immediately clear, because the crimes occurred in 1997.