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Quarles v. United States

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Supreme Court of the United States
Quarles v. United States
Term: 2018
Important Dates
Argument: April 24, 2019
Decided: June 10, 2019
Outcome
Affirmed
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Clarence Thomas


Quarles v. United States is a case argued before the Supreme Court of the United States on April 24, 2019, during the court's 2018-2019 term. It came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit.[1][2]

The case concerned the timing of intent to commit burglary under the Armed Career Criminal Act (ACCA). On June 10, 2019, the court unanimously affirmed the ruling of the United States Court of Appeals for the 6th Circuit, holding "remaining-in burglary occurs when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure."[3] Click here for more information about the opinion.

HIGHLIGHTS
  • The case: The Western District of Michigan sentenced Jamar Quarles to 204 months in prison for committing a violent felony under the ACCA. The case was appealed, vacated, and remanded. On remand, the district court again sentenced Quarles to 204 months in prison, and the 6th Circuit affirmed the ruling. The district court and the 6th Circuit agreed that Michigan law was not broader than federal law regarding the generic burglary definition from Taylor v. United States.
  • The issue: "Whether (as two circuits hold) Taylor's definition of generic burglary requires proof that intent to commit a crime was present at the time of unlawful entry or first unlawful remaining, or whether (as the court below and three other circuits hold) it is enough that the defendant formed the intent to commit a crime at any time while "remaining in" the building or structure."[4]
  • The outcome: On June 10, 2019, the court unanimously affirmed the ruling of the 6th Circuit Court of Appeals, holding "remaining-in burglary occurs when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure."[3]


    • You can review the lower court's opinion here.[5]

    Timeline

    The following timeline details key events in this case:

    • June 10, 2019: U.S. Supreme Court affirmed the ruling of the 6th Circuit
    • April 24, 2019: Oral argument
    • January 11, 2019: U.S. Supreme Court agreed to hear the case
    • November 24, 2017: Petition filed with the U.S. Supreme Court
    • March 10, 2017: 6th Circuit affirmed the Western District of Michigan's ruling

    Background

    Jamar Quarles pleaded guilty to one count of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g). The U.S. District Court for the Western District of Michigan held that Quarles had committed a violent felony under the Armed Career Criminal Act (ACCA) and sentenced him to 204 months in prison. On appeal, the 6th Circuit vacated the sentence.[5] On remand, the district court held that Michigan's crime of third-degree home invasion was a "violent felony" and the "functional equivalent of generic burglary." The court again sentenced Quarles to 204 months in prison. The 6th Circuit affirmed the district court's decision.[5]

    Federal law defines generic burglary as "an unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime." The definition came from Taylor v. United States, a case the U.S. Supreme Court decided in 1990.[6]

    Michigan law defines third-degree home invasion as (1) breaking and entering a dwelling with or without permission with intent to commit a crime or (2) breaking and entering a dwelling with or without permission and deciding to commit a crime while entering, present, or leaving in the dwelling.[5]

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    • Whether (as two circuits hold) Taylor's definition of generic burglary requires proof that intent to commit a crime was present at the time of unlawful entry or first unlawful remaining, or whether (as the court below and three other circuits hold) it is enough that the defendant formed the intent to commit a crime at any time while "remaining in" the building or structure.

    Outcome

    On June 10, 2019, the court unanimously affirmed the judgment of the 6th Circuit Court of Appeals, holding "remaining-in burglary occurs when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure."[3]

    Justice Brett Kavanaugh delivered the opinion of the court. Justice Clarence Thomas filed a concurring opinion.[3]

    Opinion

    In his opinion, Justice Kavanaugh wrote:[3]

    “ It is not likely that Congress intended generic burglary under §924(e) [the Armed Career Criminal Act] to include (i) a burglar who intends to commit a crime at the exact moment when he or she first unlawfully remains in a building or structure, but to exclude (ii) a burglar who forms the intent to commit a crime at any time while unlawfully remaining in a building or structure.


    Indeed, excluding that latter category of burglaries from generic burglary under §924(e) would make little sense in light of Congress’ rationale for specifying burglary as a violent felony. ... Burglary is dangerous because it 'creates the possibility of a violent confrontation between the offender and an occupant, caretaker, or some other person who comes to investigate.'[7]

    		”

    Concurring opinion

    Justice Thomas filed a concurring opinion.

    In his concurring opinion, Thomas wrote:[3]

    “ I join the opinion of the Court because it correctly applies our precedent requiring a 'categorical approach' to the enumerated-offenses clause of the Armed Career Criminal Act (ACCA). I write separately to question this approach altogether. ...


    Because the categorical approach employed today is difficult to apply and can yield dramatically different sentences depending on where a burglary occurred, the Court should consider whether its approach is actually required in the first place for ACCA’s enumerated-offenses clause. [7]

    		”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "Quarles v. United States," accessed March 27, 2019
    2. ↑ SCOTUSblog, "Eight new grants, Ginsburg recovery from surgery 'on track,'" January 11, 2019
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 Supreme Court of the United States, Quarles v. United States, decided June 10, 2019
    4. ↑ 4.0 4.1 Supreme Court of the United States, "Quarles v. United States: Questions presented," accessed March 27, 2019
    5. ↑ 5.0 5.1 5.2 5.3 U.S. Court of Appeals for the 6th Circuit, United States v. Quarles, May 10, 2017
    6. ↑ Oyez, "Quarles v. United States," accessed March 27, 2019
    7. ↑ 7.0 7.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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