Mathis v. United States
- Decided
- June 23, 2016
- Docket
- 15–6092.
- Status
- Published
- Jurisdiction
- Federal
Cited 2,769 timesNo negative treatment found in this library
What later courts said
- concluding that a plea agreement shows that the statutory elements constitute different elements rather than means — United States v. Wilkins (2022)
- holding that lower court erred in applying modified categorical approach to statute that contained only alternative means and therefore wasn't divisible — United States v. Degeare (2018)
- holding that another Iowa statute was not divisible because it listed “disjunctive factual scenarios” for burglary, not separate elements — United States v. Tyrone Parrow (2016)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
Justice KAGAN delivered the opinion of the Court.
The Armed Career Criminal Act (ACCA or Act), 18 U.S.C. § 924(e), imposes a 15-year mandatory minimum sentence on 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 offenses, courts compare the elements of the crime of conviction with the elements of the "generic" version of the listed offense-i.e., the offense as commonly understood. For more than 25 years, our decisions have held that the prior crime qualifies as an ACCA predicate if, but only if, its elements are the same as, or narrower than, those of the generic offense. The question in this case is *2248whether ACCA makes an exception to that rule when a defendant is convicted under a statute that lists multiple, alternative means of satisfying one (or more) of its elements. We decline to find such an exception.
I
Statutes cited
Cite this
Mathis v. United States, 579 U.S. 500 (2016)Read the full opinion
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