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Supreme Court Rules That Breaking Into Multiple Self-Storage Units Equals 1 Crime in Wooden vs. U.S.

March 9, 2022

2 Min Read
Supreme Court Rules That Breaking Into Multiple Self-Storage Units Equals 1 Crime in Wooden vs. U.S.

The U.S. Supreme Court ruled on Monday that the act of a thief who breaks into multiple units at the same self-storage facility constitutes only a single crime when applied against the enhanced-sentencing provision of the Armed Career Criminal Act (ACCA). The Court came to its conclusion in examining Wooden v. United States, a case involving William Dale Wooden, who pleaded guilty to 10 counts of burglary in 1997 and was later convicted of unlawful gun possession in 2014.

Wooden’s record as a felon stems from a 1997 incident in which he burglarized 10 units at a Dalton, Georgia, self-storage facility. Wooden had lived next door to the property at 100 Williams Road when he and three others broke into the units and stole items, crashing through the drywall between spaces. The men were charged with 10 counts of burglary under one indictment. Wooden pleaded guilty and was sentenced to eight years in prison for each conviction, with the terms to run concurrently, according to the Court’s opinion, written by Justice Elena Kagan.

In 2014, Wooden was arrested and convicted of being a felon in possession of a firearm. Though the government’s probation office recommended a sentence of 21 to 27 months, prosecutors decided to pursue an enhancement under the ACCA, which carried a mandatory minimum sentence of 15 years as long as Wooden was considered to have three prior violent felonies.

Prosecutors contended that the 10 self-storage burglary charges qualified as 10 violent felonies. Wooden’s defense argued that because the burglaries occurred on the same “occasion,” they should count as one violent felony when applied to the ACCA.

Though lower courts and the 6th U.S. Circuit Court of Appeals subsequently affirmed the government’s reasoning, the Supreme Court agreed to hear the case because appellate courts have been divided over the meaning of the ACCA’s “occasions” clause when applied in other cases.

“The question presented is whether Wooden’s prior convictions were for offenses occurring on different occasions, as the lower courts held, because the burglary of each unit happened at a distinct point in time, rather than simultaneously,” Kagan wrote. “The answer is no. Convictions arising from a single criminal episode, in the way Wooden’s did, can count only once under ACCA.”

Though the Court’s opinion was unanimous, justices Samuel Alito, Amy Coney Barrett, Neil Gorsuch and Clarence Thomas declined to join Kagan’s full opinion because they disagreed with some of her reasoning, a source reported.

Sources:
U.S. Supreme Court, Opinion of the Court, Wooden v. United States
Jurist, US Supreme Court Finds Breaking Into Multiple Storage Units Equals One Crime for Sentencing Enhancement Purposes
SCOTUS Blog, Court Rejects Enhanced Sentence Under Armed Career Criminal Act for Man Who Broke Into Storage Facility

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