Wooden v. United States, Docket No. 20-5279 Decided March 7, 2022
Supreme Court Decision: https://www.supremecourt.gov/opinions/21pdf/20-5279_09m1.pdf
The Court was asked to decide if a single crime spree counts as multiple “occasions” under Armed Career Criminal Act (ACCA). In a unanimous 9-0 opinion, the Court rejected that argument and held that William Dale Wooden’s ten burglary offenses arising from a single criminal episode did not occur on different “occasions” and thus count as only one prior conviction under the Armed Career Criminal Act.
The case dates back to 1997, when Mr. Wooden broke into a Georgia storage facility with three friends. After burgling the first unit, they broke through the drywall into the second unit and continued on through a total of ten units. The three were caught and Mr. Wooden pleaded guilty to ten counts of burglary, receiving an eight-year prison sentence, ending the case.
Seventeen years later, a plain clothes police officer looking for a fugitive wanted for misdemeanor theft knocked on Mr. Wooden’s door. He did not identify himself as a police officer. When the officer saw a rifle in his house, Mr. Wooden was arrested for being a felon in possession of a firearm in violation of state law. These state charges were eventually dropped, however, federal prosecutors decided to prosecute Mr. Wooden who was convicted for violating a federal law barring people with felony convictions from owning firearms. The probation office first recommended a sentence of 21 to 27 months. But the prosecutors argued that Mr. Wooden should be sentenced under the Armed Career Criminal Act, or ACCA, to make his sentence approximately eight times longer.
The ACCA requires judges to impose a minimum sentence of 15 years (with a maximum sentence of life) for people with felony convictions in possession of a gun. The twist in this case is that an individual qualifies for ACCA’s enhancement if they have three prior convictions for violent felonies “committed on occasions different from one another.” Although Mr. Wooden only broke the law on one previous occasion, the 1997 burglary of ten different units at the same location, the prosecutors argued that this crime was actually ten separate “occasions”—one for each unit he broke into. The judge agreed, and rather than a two-year sentence, he gave Wooden a term of nearly 16 years in prison. A federal appeals court affirmed the sentence.
In reversing and remanding the case, the Supreme Court looked at the term “occasions” and unanimously held that even though Mr. Wooden had broken into ten units, it was all on one day at one location and that constituted on “occurrence” under the ACCA.