Mathis v. United States

PETITIONER: Richard Mathis
RESPONDENT: United States
LOCATION: U.S. District Court for the Southern District of Iowa

DOCKET NO.: 15-6092
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 579 US (2016)
GRANTED: Jan 19, 2016
ARGUED: Apr 26, 2016
DECIDED: Jun 23, 2016

ADVOCATES:
Mark C. Fleming - for the petitioner
Nicole A. Saharsky - Assistant to the Solicitor General, for the respondent

Facts of the case

On March 8, 2013, police officers executed a warrant to search Richard Mathis’ house following allegations of sexual abuse from young men. The officers found a loaded rifle and ammunition. After he was arrested and while in custody, Mathis admitted to owning the rifle and ammunition, and he was charged with being a felon in possession of a firearm in violation of the Armed Career Criminal Act (ACCA) because of his five previous burglary convictions in Iowa state courts. At trial, the district court used a modified categorical approach to determine that Mathis’ prior convictions constituted violent felonies because the elements of the offense were substantially similar to generic burglary and posed the same risk of harm to others. Therefore, Mathis was sentenced to 180 months imprisonment pursuant to the ACCA. Mathis appealed his conviction and argued that his Iowa convictions should not have constituted predicate offenses under the ACCA, but the U.S. Court of Appeals for the Eighth Circuit affirmed the lower court's decision.

Question

Does a predicate prior conviction under the Armed Career Criminal Act qualify when the courts examine the specific elements of the offenses in question using a modified categorical approach?

Media for Mathis v. United States

Audio Transcription for Oral Argument - April 26, 2016 in Mathis v. United States

Audio Transcription for Opinion Announcement - June 23, 2016 in Mathis v. United States

John G. Roberts, Jr.:

Justice Kagan has our opinion this morning in case 15-6092, Mathis versus United States.

Elena Kagan:

This is a case about a federal law called the Armed Career Criminal Act which we usually call ACCA.

ACCA increases the prison sentences of certain repeat offenders who illegally own guns.

Usually, a convicted felon found carrying a gun faces a 10-year maximum sentence but under ACCA if that person has three prior convictions for a violent felony, which is defined to include burglary, he faces a 15-year mandatory minimum.

The question that often arises under ACCA is how to determine whether a person's prior conviction is four of one of the listed felonies, in this case burglary.

One thing you could do is check whether a person has a conviction for a crime “burglary”.

But the problem with that approach is states define burglary very differently.

Some states define it the way most people think of that crime, which is breaking and entering into a building but other states define it more broadly to include things like breaking into a car or even shoplifting.

And since we've always thought Congress didn't mean to increase the sentences of people who've committed those crimes that approach won't work.

Another thing you could try is looking to the facts of the defendant's crime to see what he actually did, ignore the law he was convicted under and just make a finding as to whether he actually broke into a building and therefore committed the kind of burglary Congress meant to get at with ACCA.

But it turns out there are problems with that approach too.

First, based on the text of ACCA, we don't think that's what Congress wanted.

Rather, Congress meant to treat everyone convicted of a particular crime uniformly.

Second, that approach raises constitutional concerns because it would allow a judge rather than a jury to decide what a defendant actually did.

And third, that approach gives rise to practical and fairness problems because it's often hard to make that kind of finding many years after the fact.

So for the last 25 years, we have instead applied what we call the categorical approach.

Under that approach we look at the crime the defendant was convicted of and we compare the elements of that crime to the elements of burglary as usually understood and we see if they match.

The elements of a crime are what the prosecution has to prove to convict.

So if a state's burglary law requires the prosecution to prove that the defendant broke into a building then that counts as burglary under ACCA.

But if a state's law is less demanding, if it doesn't require the prosecution to show the defendant broke into a building; for example, if it treats breaking into a car as a burglary then a conviction under that law doesn't count even if the defendant did break into a building.

If the law doesn't require the prosecution to prove that in every case the conviction doesn't count.

Now, in this case Richard Mathis had prior convictions under Iowa's Burglary Law.

The elements of that offense don't match those of the usual burglary law because Iowa doesn't require the prosecution to prove that a defendant break into a building.

Instead Iowa's Law says that the prosecution just has to prove that the defendant broke into some premises, which is statutorily defined to include not only buildings but also cars.

So under a straightforward application of the categorical approach, Mathis’ convictions shouldn't have counted as burglary under ACCA.

But the Eighth Circuit said they did.

It thought that everything changed because the Iowa Statute happens to list various ways of committing the offense.

That is the statute makes explicit that someone can burglarize either a building or a car.

The court thought that when a statute is written that way instead of just saying any premises it says any premises including a building or a car when a statute is written that way the sentencing court can take it on itself to determine whether the defendant in fact had broken into a building rather than a car.

We reverse that decision.

Sarah from Law Aspect

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