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Mathis v. United States

Justia Summary

The Armed Career Criminal Act (ACCA) imposes a 15-year mandatory minimum sentence on a defendant convicted of being a felon in possession of a firearm who has three prior convictions “for a violent felony,” including “burglary, arson, or extortion,” 18 U.S.C. 924(e). To determine whether a prior conviction is a listed crime, courts apply the “categorical approach,” asking whether the elements of the offense sufficiently match the elements of the generic (commonly understood) version of the enumerated crime. When a statute defines multiple crimes by listing multiple, alternative elements, a sentencing court must discern which of the alternative elements was integral to the defendant’s conviction, by employing the “modified categorical approach” and examining a limited class of documents from the record of a prior conviction. Mathis pleaded guilty to being a felon in possession of a firearm. He had five prior Iowa burglary convictions. Under the generic offense, burglary requires unlawful entry into a “building or other structure.” The Iowa statute (702.12) reaches “any building, structure, [or] land, water, or air vehicle.” The district court applied the modified categorical approach, found that Mathis had burgled structures, and imposed an enhanced sentence. The Eighth Circuit affirmed, reasoning that the Iowa statute’s list of places did not establish alternative elements, but rather alternative means of fulfilling a single locational element. The Supreme Court reversed. Because the elements of Iowa’s law are broader than those of generic burglary, Mathis’s prior convictions cannot give rise to ACCA’s sentence enhancement. The “underlying brute facts or means” by which the defendant commits his crime make no difference; even if the defendant’s conduct fits the generic definition, the mismatch of elements saves him from an ACCA sentence. Construing ACCA to allow a sentencing judge to go further would raise serious Sixth Amendment concerns because only a jury, not a judge, may find facts that increase the maximum penalty. A statute’s listing of disjunctive means does not mitigate the possible unfairness of basing an increased penalty on something not legally necessary to the prior conviction.

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