SCOTUS | Burglary in mobile structures for overnight accommodation included in ‘burglary’ under Armed Career Criminal Act

Supreme Court of the United States:  This appeal was filed before the Bench of Breyer, J.

The case involved two defendants who were convicted in the Federal Court for unlawful possession of firearms which was violative of § 922(g)(1) of The Armed Career Criminal Act. Each offender had State burglary convictions which could potentially expose them to a mandatory prison term of 15 years. The offenders should have at least three convictions of ‘violent felonies’ which includes ‘burglary’ as per §924(a)(1).

The issue that arose was whether the burglary of a non-permanent or mobile structure that is used for overnight accommodation qualifies as ‘burglary’ in the said Act. The Federal Court vacated the sentence of the offenders and hence an appeal was filed before the Supreme Court. The Court adjudged that the statutory term ‘burglary’ does indeed include structures used for overnight accommodation. The Court relied on Mathis v. United States, 2016 SCC OnLine US SC 80 and Taylor v. United States, 1990 SCC OnLine US SC 81 to construe the term. The judgment of the Sixth Court of Appeals was reversed and the judgment of the Eighth Circuit Court of Appeals was vacated.[United States v. Victor J. Stitt, 2018 SCC OnLine US SC 86, decided on 10-12-2018]

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