Wooden v. United States
595 U.S. 360 (2022)
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Rule of Law:
For purposes of the Armed Career Criminal Act (ACCA)'s enhanced sentencing provision, prior felony convictions are considered to have occurred on a single “occasion” when they arise from a single criminal episode, even if they involved multiple, temporally distinct activities.
Facts:
- In 1997, William Dale Wooden and three confederates unlawfully entered a single storage facility located at 100 Williams Road in Dalton, Georgia.
- The burglars proceeded to break through interior drywall, moving from unit to unit within the facility.
- They ultimately stole items from ten different storage units during this single night of activity.
- Georgia prosecutors charged Wooden with ten counts of burglary, one for each storage unit, in a single indictment as required by state law for crimes arising from the same conduct.
- Wooden pleaded guilty to all ten counts and was sentenced to eight years' imprisonment for each conviction, with the terms to run concurrently.
- In November 2014, law enforcement officers discovered several firearms in Wooden's home after he allowed an officer to enter.
- Wooden, being a convicted felon, was arrested for possessing a firearm.
- A jury subsequently convicted William Dale Wooden for being a felon in possession of a firearm in violation of federal law.
- The United States Government sought to apply the Armed Career Criminal Act (ACCA) enhancement to Wooden's sentencing, citing his ten prior burglary convictions.
Procedural Posture:
- A jury convicted William Dale Wooden of being a felon in possession of a firearm in violation of 18 U. S. C. §922(g).
- The United States Government asked the District Court (trial court) to sentence Wooden under the Armed Career Criminal Act (ACCA).
- The District Court applied ACCA's penalty enhancement, determining that Wooden had commenced a new “occasion” of criminal activity each time he left one storage unit and entered another, and sentenced him to 188 months (almost 16 years) in prison.
- William Dale Wooden appealed the District Court's sentencing decision to the United States Court of Appeals for the Sixth Circuit (intermediate appellate court).
- The Sixth Circuit affirmed the District Court's decision, reasoning that ACCA’s occasions clause is satisfied whenever crimes take place at different moments in time, that is, sequentially rather than simultaneously.
- William Dale Wooden filed a petition for a writ of certiorari with the United States Supreme Court.
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Issue:
Does a defendant's ten prior burglary convictions, stemming from a single criminal episode where he unlawfully entered one storage facility and stole from ten separate units in succession, constitute convictions “committed on occasions different from one another” under the Armed Career Criminal Act (ACCA)?
Opinions:
Majority - Elena Kagan
No, Wooden's ten burglary convictions arising from a single criminal episode did not occur on "occasions different from one another" and therefore count as only one prior conviction for purposes of ACCA. The Court found that the ordinary meaning of "occasion" refers to an event, occurrence, happening, or episode, which can encompass multiple, temporally distinct activities, much like a wedding includes various non-simultaneous events. The government's view that each offense's completion at a discrete moment constitutes a new "occasion" would largely collapse ACCA's two separate conditions (three felonies AND committed on different occasions), rendering the occasions clause superfluous for most sequential crimes. Instead, the Court established a multi-factored inquiry, considering timing (crimes committed close in time, in an uninterrupted course of conduct), location (proximity of where crimes took place), and the character and relationship of the offenses (similarity, intertwining, common scheme or purpose). Applying these factors to Wooden's case, the Court found that his burglaries occurred on a single night, in a single uninterrupted course of conduct, at one location (a single-building storage facility), with each offense being essentially identical and intertwined, and all part of the same scheme. This interpretation is reinforced by statutory history, specifically Congress's amendment of ACCA with the "occasions clause" in response to United States v. Petty, where multiple robberies in one restaurant were deemed a single criminal episode, not separate occasions for enhanced sentencing. The purpose of ACCA is to target “armed career criminals” who pose a “special danger” due to repeated criminal activity over time, a purpose not served by classifying Wooden's single criminal spree as multiple career-offender predicates.
Concurring - Sonia Sotomayor
Justice Sotomayor concurred with the majority, agreeing that the facts of the case clearly show Wooden's prior convictions did not take place on "occasions different from one another." She further noted that any questions about the clarity of the record below only highlight the government's failure to prove the enhancement applies. Additionally, Justice Sotomayor agreed with Justice Gorsuch that the rule of lenity provides an independent basis for ruling in favor of a defendant in a closer case, and joined Parts II-IV of his opinion.
Concurring - Brett Kavanaugh
Justice Kavanaugh joined the majority opinion in full. He wrote separately to clarify that the rule of lenity applies only when a federal criminal statute is "grievously ambiguous" after exhausting all traditional tools of statutory interpretation, and therefore rarely, if ever, comes into play as a decisive factor. He argued against expanding the rule of lenity's application, suggesting that concerns for fair notice in federal criminal law are better addressed by the presumption of mens rea (requiring the government to prove the defendant's state of mind regarding each element of an offense) or allowing for a mistake-of-law defense in certain circumstances.
Concurring in part and concurring in judgment - Amy Coney Barrett
Justice Barrett concurred in part with the majority's judgment and reasoning, joining all but Part II-B of the opinion. She agreed with the Court's analysis of the ordinary meaning of "occasion" and its conclusion that Wooden's burglaries count only once under ACCA. However, she disagreed with the majority's reliance on legislative history, specifically the Solicitor General's brief in United States v. Petty, to interpret the "occasions clause." She argued that this approach depends on flawed inferences, elevating legislative and litigation history to the status of a governing test, which is not how statutory interpretation should work and risks sowing unnecessary confusion by inviting courts to mine old briefs for guidance rather than focusing solely on the words of the statute.
Concurring in judgment - Neil Gorsuch
Justice Gorsuch concurred in the judgment, agreeing with the outcome that Wooden's convictions should count as a single occasion, but criticized the majority's multi-factor balancing test as providing "notoriously little guidance" and perpetuating confusion in lower courts. He argued that such tests lead to unpredictable and inconsistent results, especially in hard cases where factors may point in different directions. Justice Gorsuch contended that where reasonable doubt exists about the application of a penal law, the rule of lenity demands a judgment in favor of liberty. He asserted that the rule of lenity, rooted in due process (fair notice) and separation of powers (legislature defines crimes), should apply when there are "reasonable doubts" about a statute's meaning, not just "grievous" ambiguities, and that judges should not use legislative history or perceived statutory purpose to expand punishment under ambiguous laws. Justice Sotomayor joined Parts II, III, and IV of this opinion.
Analysis:
This decision significantly clarifies the application of the Armed Career Criminal Act's "occasions clause," rejecting a strict temporal, elements-based interpretation in favor of a more holistic, multi-factor analysis. By emphasizing timing, location, and the character/relationship of offenses, the Court aims to align ACCA's enhanced sentencing provisions with its original purpose of targeting habitual, truly recidivist offenders who commit distinct criminal episodes. This shift will likely limit the number of defendants subjected to ACCA's mandatory 15-year minimum, particularly those whose multiple convictions arise from a single, continuous criminal spree. However, the multi-factor test, while more flexible, introduces new complexities and potential for litigation as lower courts grapple with weighing these factors, particularly in cases that are not as clear-cut as Wooden's.
