Supreme Court Rules Man Who Stole From 10 Different Storage Units Committed 1 Crime, Not Multiple

The Supreme Court ruled unanimously Monday to throw out a federal sentencing enhancement handed to a Tennessee man based on how the lower courts interpreted his prior conviction on 10 counts of burglary.

In 2015, William Dale Wooden was sentenced to 15 years in prison for possessing a firearm as a felon under the Armed Criminal Career Act. The federal statute imposes a 15-year minimum sentence for illegal gun possession if a defendant has three or more prior convictions “committed on occasions different from one another.”

Central to Wooden’s case was whether stealing items from 10 different storage units at a single Georgia facility during one night in 1997 were committed on different occasions or during one single offense.

“The answer is no. Convictions arising from a single criminal episode, in the way Wooden’s did, can count only once under ACCA,” Justice Elena Kagan wrote in the opinion.

Federal prosecutors had argued that Wooden committed a new “occasion” of criminal activity each time he left one storage unit and entered another. 

Wooden’s other prior convictions include a 1989 aggravated assault and a 2005 burglary.

Though the decision was unanimous, four justices — Clarence Thomas, Samuel Alito, Neil Gorsuch, and Amy Coney Barrett — declined to join all of Kagan’s opinion, meaning they disagreed with some of her reasoning.

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