Wooden v. United States

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Supreme Court of the United States
Wooden v. United States
Term: 2021
Important Dates
Argued: October 4, 2021
Decided: March 7, 2022
Outcome
Pending
Vote
9-0
Majority
Elena Kagan • Chief Justice John Roberts • Stephen Breyer • Sonia Sotomayor • Brett Kavanaugh (in full);
Clarence Thomas • Samuel Alito • Amy Coney Barrett (all but Part II-B)
Concurring
Sonia Sotomayor;
Neil Gorsuch • Sonia Sotomayor (Gorsuch concurring in the judgment, Sotomayor joined as to Part II, III, and IV);
Brett Kavanaugh;
Amy Coney Barrett • Clarence Thomas (concurring in part and concurring in the judgment)

Wooden v. United States is a case that was decided by the Supreme Court of the United States on March 7, 2022, during the court's October 2021-2022 term. The case was argued before the court on October 4, 2021.

In a unanimous ruling, the court reversed the Sixth Circuit's ruling and remanded the case for further proceedings, holding that William Wooden's 10 offenses did not occur on different occasions and count as one prior conviction under the Armed Career Criminal Act (ACCA). Justice Elena Kagan delivered the majority opinion of the court. Chief Justice John Roberts and Justices Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh joined the opinion in full. Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett joined all but Part II-B. Justice Sotomayor filed a concurring opinion. Justice Neil Gorsuch filed an opinion concurring in the judgment, joined by Justice Sotomayor as to Part II, III, and IV. Justice Kavanaugh filed a concurring opinion. Justice Barrett filed an opinion concurring in part and concurring in the judgment, joined by Justice Thomas.[1] Click here for more information about the ruling.


HIGHLIGHTS
  • The case: In November 2015, Conway Mason, a sheriff's department investigator in Monroe County, Tennessee, approached William Wooden and Janet Harris' residence as part of a search for fugitive Ben Harrelson. Mason asked to enter the home to stay warm. Wooden allowed him entry while he went to find Harris. Wooden retrieved a firearm in the hallway. Mason knew Wooden had previously been convicted of committing felony offenses. Officers advised Wooden to put down his weapon and confiscated the firearm. Then, they searched the home and discovered two more guns along with ammunition. In federal district court, Wooden was charged with being a felon in possession of firearms. Wooden requested that the evidence discovered during the search of his home be excluded from trial because the officers entered his home without a warrant and without his consent in violation of the Fourth Amendment to the United States Constitution. The Eastern District of Tennessee rejected his motions. At sentencing, Wooden was charged under the Armed Career Criminal Act (ACCA) due to his previous felony convictions. Wooden argued that his previous convictions did not qualify under the ACCA. The district court disagreed and on appeal, the United States Court of Appeals for the 6th Circuit affirmed the lower court's ruling. Click here to learn more about the case's background.
  • The issues: The case concerned the Fourth Amendment to the United States Constitution and how predicate offenses are considered and classified under the Armed Career Criminal Act. A predicate offense is a crime that may be or may be considered a component of a larger crime.
  • The questions presented:
    "1. Did the warrantless entry and search of petitioner's home violate his Fourth Amendment right to be free from illegal search and seizure?
    "2. Did the Sixth Circuit err by expanding the scope of 18 U.S.C. §924(e)(1) in the absence of clear statutory definition with regard to the vague term 'committed on occasions different from one another'?"[2]
  • The outcome: The U.S. Supreme Court reversed the Sixth Circuit's ruling and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 6th Circuit. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    Background

    In November 2015, Monroe County, Tennessee, Sheriff's Department investigator Conway Mason, along with two other officers, approached the home of William Wooden. The officers were searching for a fugitive, Ben Harrelson, and believed that he might be inside Wooden's residence. Janet Harris also lived in the home. Mason was not wearing his uniform. He knocked on the door and asked to speak with Harris and if he could step inside to stay warm. Wooden said yes and went to find Harris. Mason saw Wooden retrieve a firearm. The officers told Wooden to put the weapon down, and he complied. Mason knew Wooden had previously been convicted of felony offenses. He confiscated the rifle, handcuffed, and searched Wooden, finding a loaded revolver handgun. Harris gave the officers permission to search the home, and the officers discovered a third firearm. Wooden later admitted that he possessed all three firearms and the ammunition. The officers did not find Harrelson in the home.[3][4]

    In federal district court, prosecutors charged Wooden with being a felon in possession of firearms and ammunition. Wooden moved to suppress, or exclude, the evidence discovered during the search of his home, arguing that the officers violated his Fourth Amendment rights by entering his home without a warrant or his consent. The court denied the motion, concluding that Wooden had given consent allowing the officers' entry. Wooden was convicted in a jury trial.[3]

    During sentencing proceedings, the probation office report indicated that Wooden was classified as an armed career criminal under the Armed Career Criminal Act (ACCA) because he had more than three prior convictions for violent felonies: an aggravated assault in 1989, 10 burglaries in 1997, and a burglary in 2005. Wooden objected to the classification, arguing that the 1989 and 2005 offenses did not qualify as violent felonies and that the 10 burglaries in 1997 arose out of a single occasion and as such were a single predicate crime under the ACCA, meaning that the burglaries constituted only one legal instance on which to base the current classification, rather than 10 instances. The Eastern District of Tennessee rejected Wooden's objections, holding that the 2005 burglary did qualify as a violent felony and that the 10 burglaries qualified as 10 predicate offenses under the ACCA.[3]

    Wooden appealed to the United States Court of Appeals for the 6th Circuit. In his appeal, Wooden claimed that the government failed to prove that Wooden knew he was a convicted felon, citing the U.S. Supreme Court's ruling in Rehaif v. United States. On appeal, the 6th Circuit affirmed the Eastern District of Tennessee's ruling, holding that the district court was correct in denying Wooden's motion to suppress and that Wooden's 10 burglary convictions were each predicate offenses under the ACCA. Wooden appealed to the Supreme Court of the United States.[3]

    Armed Career Criminal Act

    The text of the Armed Career Criminal Act, at issue in this case, reads as follows:[5]

    “ In the case of a person who violates section 922(g) of this title and has three previous convictions by any court referred to in section 922(g)(1) of this title for a violent felony or a serious drug offense, or both, committed on occasions different from one another, such person shall be fined under this title and imprisoned not less than fifteen years, and, notwithstanding any other provision of law, the court shall not suspend the sentence of, or grant a probationary sentence to, such person with respect to the conviction under section 922(g).[6] ”

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Did the warrantless entry and search of petitioner's home violate his Fourth Amendment right to be free from illegal search and seizure?
    2. Did the Sixth Circuit err by expanding the scope of 18 U.S.C. §924(e)(1) in the absence of clear statutory definition with regard to the vague term 'committed on occasions different from one another'?[6]     		”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a unanimous ruling, the court reversed the Sixth Circuit's ruling and remanded the case for further proceedings, holding that William Wooden's 10 offenses did not occur on different occasions and count as one prior conviction under the Armed Career Criminal Act (ACCA). Justice Elena Kagan delivered the majority opinion of the court. Chief Justice John Roberts and Justices Stephen Breyer, Sonia Sotomayor, and Brett Kavanaugh joined the opinion in full. Justices Clarence Thomas, Samuel Alito, and Amy Coney Barrett joined all but Part II-B. Justice Sotomayor filed a concurring opinion. Justice Neil Gorsuch filed an opinion concurring in the judgment, joined by Justice Sotomayor as to Part II, III, and IV. Justice Kavanaugh filed a concurring opinion. Justice Barrett filed an opinion concurring in part and concurring in the judgment, joined by Justice Thomas.[1]

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    “ In the course of one evening, William Dale Wooden burglarized ten units in a single storage facility. He later pleaded guilty, for that night’s work, to ten counts of burglary—one for each storage unit he had entered. Some two decades later, the courts below concluded that those convictions were enough to subject Wooden to enhanced criminal penalties under the Armed Career Criminal Act (ACCA). That statute mandates a 15-year minimum sentence for unlawful gun possession when the offender has three or more prior convictions for violent felonies like burglary “committed on occasions different from one another.” 18 U. S. C. §924(e)(1). The question presented is whether Wooden’s prior convictions were for offenses occurring on different occasions, as the lower courts held, because the burglary of each unit happened at a distinct point in time, rather than simultaneously. The answer is no. Convictions arising from a single criminal episode, in the way Wooden’s did, can count only once under ACCA.[6] ”
    —Justice Elena Kagan

    Concurring opinion

    Justice Sotomayor

    Justice Sonia Sotomayor filed a concurring opinion.

    In her concurring opinion, Justice Sotomayor wrote:[1]

    “ I join the opinion of the Court because on the facts of this case, it is clear that Wooden’s prior convictions did not take place “on occasions different from one another,” as required for the sentencing enhancement to apply. 18 U.S.C. §924(e)(1). JUSTICE GORSUCH raises questions about the clarity of the record below, but in my view, those questions only underscore the Government’s failure to carry its burden of proving the enhancement’s application. See Pereida v. Wilkinson, 592 U. S. ___, ___ (2021) (slip op., at 14) (citing Johnson v. United States, 559 U. S. 133, 137 (2010)). I agree with JUSTICE GORSUCH, however, that the rule of lenity provides an independent basis for ruling in favor of a defendant in a closer case, and I join Parts II–IV of his opinion concurring in the judgment.[6] ”
    —Justice Sonia Sotomayor

    Justice Gorsuch

    Justice Neil Gorsuch filed a concurring opinion, joined by Justice Sotomayor.

    In his concurring opinion, Justice Gorsuch wrote:[1]

    “ Once more we confront the Armed Career Criminal Act. Disputes over the statute’s meaning have occupied so much of this Court’s attention over so many years that various pieces of the law and doctrines associated with it have earned their own nicknames—the Elements Clause, the Residual Clause, the Categorical Approach. Now comes the Occasions Clause. This subsection requires courts to impose 15-year mandatory minimum prison sentences on individuals who unlawfully possess a gun if they also have three or more prior convictions for certain crimes “committed on occasions different from one another.” 18 U.S.C. § 924(e)(1). For years, lower courts have struggled with the Occasions Clause, reaching contradictory judgments on similar facts. We took this case hoping to bring some clarity to at least this particular corner of the ACCA.


    ... Respectfully, all this suggests to me that the key to this case does not lie as much in a multiplicity of factors as it does in the rule of lenity. Under that rule, any reasonable doubt about the application of a penal law must be resolved in favor of liberty. Because reasonable minds could differ (as they have differed) on the question whether Mr. Wooden’s crimes took place on one occasion or many, the rule of lenity demands a judgment in his favor. The rule seems destined as well to play an important role in many other cases under the Occasions Clause—a setting where the statute at issue supplies little guidance, does not define its key term, and the word it does use (“occasions”) can lead different people to different intuitions about the same set of facts. No list of factors, however thoughtful, can resolve every case under a law like that. Many ambiguous cases are sure to arise. In them, a rule of decision is required— and lenity supplies it.

    The “rule of lenity” is a new name for an old idea—the notion that “penal laws should be construed strictly.” The Adventure, 1 F. Cas. 202, 204 (No. 93) (CC Va. 1812) (Marshall, C. J.).

    ... The rule of lenity has a critical role to play in cases under the Occasions Clause. The statute contains little guidance, and reasonable doubts about its application will arise often. When they do, they should be resolved in favor of liberty. Today, the Court does not consult lenity’s rule, but neither does it forbid lower courts from doing so in doubtful cases. That course is the sound course. Under our rule of law, punishments should never be products of judicial conjecture about this factor or that one. They should come only with the assent of the people’s elected representatives and in laws clear enough to supply “fair warning . . . to the world.” McBoyle, 283 U.S., at 27.[6]

    		”
    —Justice Neil Gorsuch

    Justice Kavanaugh

    Justice Brett Kavanaugh filed a concurring opinion.

    In his concurring opinion, Justice Kavanaugh wrote:[1]

    “ I join the Court’s opinion in full. In light of JUSTICE GORSUCH ’s thoughtful concurrence in the judgment, I write separately to briefly explain why the rule of lenity has appropriately played only a very limited role in this Court’s criminal case law. And I further explain how another principle—the presumption of mens rea—can address JUSTICE GORSUCH ’s important concern, which I share, about fair notice in federal criminal law.


    ... In sum, I would not invite the inconsistency, unpredictability, and unfairness that would result from expanding the rule of lenity beyond its very limited place in the Court’s case law. I would, however, continue to vigorously apply (and where appropriate, extend) mens rea requirements, which as Justice Robert Jackson remarked, are “as universal and persistent in mature systems of law as belief in freedom of the human will and a consequent ability and duty of the normal individual to choose between good and evil.” Id., at 250.[6]

    		”
    —Justice Brett Kavanaugh

    Justice Barrett

    Justice Amy Coney Barrett filed a concurring opinion, joined by Justice Clarence Thomas.

    In her concurring opinion, Justice Barrett wrote:[1]

    “ I join all but Part II–B of the Court’s opinion. I agree with the Court’s analysis of the ordinary meaning of the word “occasion” and its conclusion that Wooden’s burglaries count only once under the Armed Career Criminal Act. But I do not share the Court’s view that Congress ratified the Solicitor General’s brief confessing error in United States v. Petty, 798 F. 2d 1157 (CA8 1986), when it amended the Act to add the occasions clause. This argument depends on two flawed inferences: first, that Congress specifically intended to reject the Eighth Circuit’s initial decision in Petty, and second, that it embraced the former Solicitor General’s reasoning for why that decision was wrong. The latter error, in particular, is likely to work mischief down the line.[6] ”
    —Justice Amy Coney Barrett

    Text of the opinion

    Read the full opinion here.


    October term 2021-2022

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 U.S. Supreme Court, Wooden v. United States, decided March 7, 2022
    2. ↑ 2.0 2.1 U.S. Supreme Court, "Wooden v. United States: Petition for a writ of certiorari," accessed February 22, 2021
    3. ↑ 3.0 3.1 3.2 3.3 3.4 United States Court of Appeals for the 6th Circuit, United States v. Wooden, decided December 19, 2019
    4. ↑ United States District Court for the Eastern District of Tennessee, United States v. Wooden, decided November 24, 2015
    5. ↑ Casetext, "18 U.S.C. § 924," accessed February 22, 2021
    6. ↑ 6.0 6.1 6.2 6.3 6.4 6.5 6.6 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 4, 2021
    8. ↑ Supreme Court of the United States, "Wooden v. United States - oral argument transcript," accessed October 4, 2021
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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