Taylor v. United States
495 U.S. 575 (1990)
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Rule of Law:
For the purpose of sentence enhancement under the Armed Career Criminal Act, 18 U.S.C. § 924(e), the term 'burglary' refers to a uniform, generic definition of the offense, not the definition provided by the state of conviction. The generic definition includes, at a minimum, the elements of an unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a crime.
Facts:
- Arthur Lajuane Taylor had four prior felony convictions.
- One of his prior convictions was for robbery and another was for assault.
- Two of his prior convictions, from 1963 and 1971, were for second-degree burglary under Missouri law.
- In 1988, Taylor, a convicted felon, possessed a firearm.
Procedural Posture:
- Arthur Lajuane Taylor pleaded guilty in the United States District Court for the Eastern District of Missouri to being a felon in possession of a firearm.
- The government sought a sentence enhancement under 18 U.S.C. § 924(e) based on Taylor's prior convictions, including two for second-degree burglary.
- Taylor's guilty plea was conditioned on his right to appeal the issue of whether his burglary convictions qualified as predicate offenses.
- The District Court applied the enhancement and sentenced Taylor to 15 years' imprisonment.
- Taylor, as appellant, appealed to the United States Court of Appeals for the Eighth Circuit, with the United States as appellee.
- The Eighth Circuit affirmed the sentence, holding that the meaning of 'burglary' depends on the definition used by the state of conviction.
- The United States Supreme Court granted Taylor's petition for a writ of certiorari to resolve a conflict among the circuit courts.
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Issue:
Does the term 'burglary' in the sentence enhancement provision of the Armed Career Criminal Act, 18 U.S.C. § 924(e), refer to the definition provided by the state of prior conviction, or does it require a uniform, federal definition?
Opinions:
Majority - Justice Blackmun
No, the term 'burglary' does not depend on the state of conviction's definition; it requires a uniform, generic, contemporary federal definition. Adopting the definition from the state of conviction would lead to inconsistent and arbitrary applications of federal law, where identical conduct would trigger the enhancement in one state but not another. Congress intended a uniform, categorical approach focused on the inherent risk of violence in burglary. The Court rejects the arcane common-law definition as ill-suited to modern criminal law and rejects the petitioner's proposal to limit the term to only burglaries with explicit elements of danger, as Congress's specific inclusion of 'burglary' indicates it viewed all generic burglaries as posing a serious potential risk. Therefore, the court defines generic burglary as any crime having the basic elements of unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a crime. To apply this, courts must use a 'categorical approach,' looking to the statutory elements of the prior offense rather than the particular facts of the crime.
Concurring - Justice Scalia
I agree with the Court's judgment and its textual interpretation but object to its extensive reliance on legislative history. The meaning of the statutory term 'burglary' is clear enough to be determined from the text itself, making the lengthy examination of legislative reports and witness testimony unnecessary. If the statutory language is so clear that it cannot be narrowed by the rule of lenity, it is certainly not ambiguous enough to be altered by 'legislative incunabula.' The Court should find a better way to demonstrate its conscientiousness than by engaging in a pointless ten-page discussion of legislative history.
Analysis:
This landmark decision established the 'categorical approach' as the primary method for determining whether a prior conviction qualifies as a predicate offense under the Armed Career Criminal Act (ACCA). By creating a uniform federal definition for 'burglary,' the Court ensured consistent application of the statute nationwide, preventing sentencing outcomes from depending on the peculiarities of state criminal codes. The ruling has had a profound and lasting impact on federal sentencing law, shaping how courts analyze prior convictions not only for burglary but for other enumerated offenses, and leading to decades of subsequent litigation over the scope of both the categorical and the 'modified categorical' approaches.
