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United States v. Sims

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Supreme Court of the United States
United States v. Sims
Term: 2018
Important Dates
Argument: October 4, 2017
Decided: December 10, 2018
Outcome
Eighth Circuit Court vacated and remanded
Vote
9-0 to vacate and remand
Majority
Chief Justice John G. RobertsAnthony KennedyClarence ThomasRuth Bader GinsburgStephen BreyerSamuel AlitoSonia SotomayorElena KaganNeil GorsuchBrett Kavanaugh

United States v. Sims is a case argued during the 2018-2019 term of the U.S. Supreme Court. Argument in the case was held on October 4, 2018. The case came on a writ of certiorari to the United States Court of Appeals for the 8th Circuit. The court consolidated arguments in the case with arguments in U.S. v. Stitt. The court vacated the ruling of the Eighth Circuit, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."[1][2][3]

HIGHLIGHTS
  • The case: After Jason Daniel Sims pleaded guilty to being a felon in possession of a firearm, he received an enhanced sentence under the Armed Career Criminal Act (ACCA). The ACCA applies to felons who possess a firearm and “who also have at least three prior convictions for a violent felony or serious drug offense.” Sims argued that his two prior Arkansas residential burglary convictions did not qualify as violent felonies because Arkansas’ definition of residential burglary is broader than the definition of generic burglary. The United States Court of Appeals for the 8th Circuit agreed and vacated the lower court’s ruling.[4]
  • The issue: Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as “burglary” under the Armed Career Criminal Act of 1984, 18 U.S.C. § 924(e)(2)(B)(ii).[5]
  • The outcome: The court vacated the ruling, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."

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

    Timeline

    The following timeline details key events in this case:

    • December 10, 2018: The court vacated the ruling of the Eighth Circuit Court and remanded the case
    • October 9, 2018: Oral argument
    • April 23, 2018: U.S. Supreme Court agreed to hear case; consolidated with U.S. v. Stitt
    • November 21, 2017: Petition filed with U.S. Supreme Court
    • April 27, 2017: Eighth Circuit vacated Sims’ sentence and remanded for resentencing

    Background

    Jason Daniel Sims pleaded guilty to being a felon in possession of a firearm and received an enhanced sentence under the Armed Career Criminal Act (ACCA). The ACCA applies to felons who possess a firearm and “who also have at least three prior convictions for a violent felony or serious drug offense.” Sims argued that his two prior Arkansas residential burglary convictions did not qualify as violent felonies because Arkansas’ definition of residential burglary is broader than the definition of generic burglary.[4]

    According to a ruling issued by United States Court of Appeals for the 8th Circuit Judge Raymond Gruender, “Sims’s central contention is that generic burglary’s ‘building or structure’ element does not encompass vehicles, and thus, the Arkansas residential burglary statute sweeps more broadly than generic burglary.” The court agreed with Sims, and on April 27, 2017, the United States Court of Appeals for the 8th Circuit vacated Sims’s sentence and remanded for resentencing.[4]

    Questions presented

    The petitioner presented the following questions to the court:[6]

    Questions presented:
    • Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as "burglary" under the Armed Career Criminal Act of 1984, 18 U.S.C. 924(e)(2)(B)(ii).

    Audio

    • Audio of oral argument:[7]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Stephen Breyer delivered the unanimous opinion of the court. The court reversed the ruling of the Sixth Circuit Court, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."[3]

    Opinion

    In his opinion for the court, Justice Breyer explained that vehicles are within the scope of structures. He wrote,

    The relevant language of the Tennessee and Arkansas statutes falls within the scope of generic burglary’s definition as set forth in Taylor. For one thing, we made clear in Taylor that Congress intended the definition of 'burglary' to reflect 'the generic sense in which the term [was] used in the criminal codes of most States' at the time the Act was passed. Ibid. In 1986, a majority of state burglary statutes covered vehicles adapted or customarily used for lodging—either explicitly or by defining 'building' or 'structure' to include those vehicles.[8]

    Transcript of opinion

    • Read the opinion transcript here.

    See also

    External links

    Footnotes