Wooden v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Wooden v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Wooden v. United States.
The Supreme Court reviewed whether Wooden's ten burglary convictions from a single criminal episode should count as separate offenses under the Armed Career Criminal Act (ACCA). The Court determined that these offenses did not occur on different 'occasions' and thus should be considered as one prior conviction for ACCA purposes. This decision reversed the Sixth Circuit's affirmation of the enhanced sentence.
Holding
The single most important “bottom line” of what the Court decided in Wooden v. United States.
The Court held that Wooden's ten burglary offenses arising from a single criminal episode did not occur on different 'occasions' and thus count as only one prior conviction for ACCA purposes.
Constitutional Concepts
These are the Constitution-related themes that appear in Wooden v. United States. Click a concept to see other cases that involve the same idea.
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Why Cruel and Unusual Punishment is relevant to Wooden v. United States
The case involves the interpretation of the Armed Career Criminal Act (ACCA) and whether the enhancement of Wooden's sentence was appropriate, which implicates concerns about disproportionate punishment.
Syllabus excerpt (verbatim)The resulting sentence was almost sixteen years, much higher than the statutory maximum for Wooden's crime absent such an enhancement.
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Why Double Jeopardy is relevant to Wooden v. United States
The case discusses whether multiple convictions from a single criminal episode should count as separate offenses for sentencing enhancement under ACCA, which relates to concerns about multiple punishments for the same offense.
Syllabus excerpt (verbatim)Wooden's ten burglary offenses arising from a single criminal episode did not occur on different 'occasions' and thus count as only one prior conviction for purposes of ACCA.
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Why Void for Vagueness is relevant to Wooden v. United States
The interpretation of 'occasions different from one another' in ACCA could raise vagueness concerns, as the Court's decision hinges on the ordinary meaning of 'occasion' and its application.
Syllabus excerpt (verbatim)Given what 'occasion' ordinarily means, whether criminal activities occurred on one occasion or different occasions requires a multi-factored inquiry.
Key Quotes
Short excerpts from the syllabus in Wooden v. United States that support the summary and concepts above.
Wooden's ten burglary offenses arising from a single criminal episode did not occur on different 'occasions' and thus count as only one prior conviction for purposes of ACCA.
An ordinary person using language in its normal way would describe Wooden's entries into the storage units as happening on a single occasion.
The Government's approach would largely collapse the two conditions and give ACCA's three-occasions requirement no work to do.