Matthew Robert Descamps, Petitioner v. United States (570 U.S. 254)
U.S. Supreme Court · decided June 20, 2013 · Supreme Court Database (Spaeth)
- Citation
- 570 U.S. 254 · 133 S. Ct. 2276
- Decided
- June 20, 2013
- Term
- October Term 2012
- Vote
- 8–1
- Majority author
- Justice Kagan
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice KAGAN delivered the opinion of the Court. The Armed Career Criminal Act (ACCA or Act), 18 U.S.C. § 924(e), increases the sentences of certain federal defendants who have three prior convictions "for a violent felony," including "burglary, arson, or extortion." To determine whether a past conviction is for one of those crimes, courts use what has become known as the "categorical approach": They compare the elements of the statute forming the basis of the defendant's conviction with the elements of the "generic" crime-i.e., the offense as commonly understood. The prior conviction qualifies as an ACCA predicate only if the statute's elements are the same as, or narrower than, those of the generic offense. We have previously approved a variant of this method-labeled (not very inventively) the "modified categorical approach"-when a prior conviction is for violating a so-called "divisible statute." That kind of statute sets out one or more elements of the offense in the alternative-for example, stating that burglary involves entry into a building or an automobile. If one alternative (say, a building) matches an element in the generic offense, but the other (say, an automobile) does not, the modified categorical approach permits sentencing courts to consult a limited class of documents, such as indictments and jury instructions, to determine which alternative formed the…
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