Mathis v. U.S.
579 U. S. ____ (2016) (2016)
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Rule of Law:
Under the Armed Career Criminal Act's categorical approach, a prior conviction qualifies as a predicate offense only if the crime's statutory elements are the same as, or narrower than, those of the generic federal offense. The modified categorical approach cannot be used to look into the facts of a prior conviction to determine the means by which a defendant committed a crime when the statute of conviction is indivisible and overbroad.
Facts:
- Richard Mathis had five prior convictions for burglary under Iowa law.
- The Armed Career Criminal Act (ACCA) imposes a mandatory minimum sentence for felons in possession of a firearm who have three prior convictions for a "violent felony," including generic burglary.
- Generic burglary under ACCA requires entry into a "building or other structure."
- Iowa's burglary statute criminalizes entry into a broader range of places, including "any building, structure, land, water, or air vehicle."
- The Iowa Supreme Court had previously held that the listed locations in its burglary statute are alternative "means" of committing a single crime, not separate "elements" defining different crimes.
Procedural Posture:
- Richard Mathis pleaded guilty in the U.S. District Court for the Southern District of Iowa to being a felon in possession of a firearm.
- The government requested an enhanced sentence under the Armed Career Criminal Act (ACCA), citing Mathis's prior Iowa burglary convictions.
- The District Court applied the modified categorical approach, examined the records of Mathis's prior convictions, and determined he had burgled structures, thus qualifying for the ACCA enhancement.
- Mathis appealed the sentence to the U.S. Court of Appeals for the Eighth Circuit.
- The Eighth Circuit affirmed the District Court's sentence, holding that the modified categorical approach applies regardless of whether the statutory alternatives are 'elements' or 'means'.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
When a criminal statute lists alternative factual means of committing a single element, and the statute as a whole is broader than the generic federal offense, may a sentencing court apply the modified categorical approach to look at the facts of a prior conviction to determine if the defendant's specific conduct matched the generic offense?
Opinions:
Majority - Justice Kagan
No. A sentencing court may not apply the modified categorical approach to investigate the factual means by which a defendant committed a crime. Under the long-established categorical approach, a state crime qualifies as an ACCA predicate only if its elements are the same as, or narrower than, the generic offense. The specific facts or means of commission are irrelevant. The modified categorical approach is a tool used only to determine which element in a divisible statute (one with alternative elements defining separate crimes) was the basis of the conviction. It is not a tool for discovering the facts underlying a conviction under an indivisible, overbroad statute. This elements-only focus is supported by ACCA's text, avoids Sixth Amendment concerns under Apprendi v. New Jersey, and prevents unfairness to defendants who would have had no reason to contest non-elemental facts at the time of their conviction.
Concurring - Justice Kennedy
Yes, based on precedent. While joining the majority opinion because it is required by the Court's precedents like Taylor and Descamps, the elements-based approach produces arbitrary and inequitable results that Congress could not have intended. Continued congressional inaction in the face of this unworkable system should require the Court to revisit its precedents in a future case. However, the reasoning should be based on statutory interpretation, not the Sixth Amendment precedent of Apprendi, which was incorrectly decided.
Concurring - Justice Thomas
Yes, to limit a constitutional violation. The Court's opinion faithfully applies precedent and rightly refuses to extend the modified categorical approach to finding facts about the means of a crime. The entire practice of judges finding facts about prior convictions to increase sentences (the Almendarez-Torres exception to Apprendi) violates the Sixth Amendment right to a jury trial. By limiting the scope of this judicial fact-finding, the Court's decision avoids further extending an unconstitutional practice.
Dissenting - Justice Breyer
Yes. The distinction between 'elements' and 'means' should not matter for sentencing purposes under ACCA, as it is a distinction without a difference in this context. The Court's decision unnecessarily complicates sentencing law and frustrates Congress's intent. Precedent, particularly Taylor v. United States, allows a sentencing court to look at charging documents to determine what the jury necessarily found, and that logic should apply whether the statutory alternatives are labeled elements or means. The majority's approach is impractical and will create time-consuming legal tangles for lower courts.
Dissenting - Justice Alito
Yes. The Court's entire line of ACCA jurisprudence, starting with Taylor, has gone off course, leading to absurd results that Congress never intended. The majority's insistence on a formalistic distinction between 'elements' and 'means' is a pointless and unworkable inquiry for sentencing judges. A practical, real-world approach would allow a sentencing court to examine the record to see if the defendant's actual conduct clearly constituted generic burglary, rather than disqualify a conviction based on abstract statutory analysis.
Analysis:
This decision reinforces and clarifies the Court's strict adherence to the elements-based categorical approach for sentencing enhancements under ACCA. By firmly distinguishing between statutory 'elements' and 'means,' Mathis significantly limits the application of the 'modified categorical approach,' restricting its use to only divisible statutes. This clarification prevents courts from delving into the specific facts of a defendant's prior conduct for indivisible, overbroad statutes, which will likely result in fewer ACCA enhancements for crimes like burglary in states with broadly written statutes. The decision solidifies a formalistic, rather than factual, inquiry, prioritizing legal certainty and Sixth Amendment concerns over a case-by-case analysis of a defendant's actual past conduct.
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