Wooden v. United States, (2022), was a Supreme Court of the United States case dealing with the Armed Career Criminal Act (ACCA). In a unanimous decision, the court ruled that multiple criminal offenses that a person commits during a single criminal episode do not count as separate convictions when considering the number of prior convictions a criminal has under the ACCA.
Background.
In 1997, William Wooden was involved with the burglary of a self-storage space, breaking into ten adjacent units within a single night. He was convicted on ten counts of burglary and served an eight-year prison sentence. Later, in 2014, Wooden was arrested for possession of a rifle under Georgia law when a police officer, out of uniform and without a warrant, entered his home and discovered the rifle. The charges were later dismissed due to the irregularities of the discovery, but federal officers stepped in to charge Wooden for possession of firearms under the ACCA. While a first-time conviction under the ACCA would normally lead to a sentence of 21 to 27 months, federal prosecutors believed that the ten prior convictions from the storage burglary were separate "occasions" under the ACCA, and triggered the enhanced sentencing provision of the ACCA for criminals that have been convictions on three or more separate occasions, setting a minimum sentence of 15 years.
While Wooden argued that the ten burglary convictions should be treated as a single occasion for purposes of the ACCA, the United States District Court for the Eastern District of Tennessee found in favor of the government's argument, as this stance was based on current case law for the Sixth Circuit. The decision was upheld on appeal at the Sixth Circuit.
