Quarles v. United States of America

Summarized by:

  • Court: U.S. Supreme Court Certiorari Granted
  • Area(s) of Law: Criminal Law
  • Date Filed: January 11, 2019
  • Case #: 17-778
  • Judge(s)/Court Below: 850 F.3d 836 (6th Cir. 2017).
  • Full Text Opinion

Whether Taylor's definition of generic burglary requires proof that intent to commit a crime was present at the time of unlawful entry or first unlawful remaining, or whether it is enough that the defendant formed the intent to commit a crime at any time while “remaining in” the building or structure.

Petitioner pleaded guilty to being a felon in possession of a firearm. He sought the court’s determination whether a prior conviction for Home Invasion in the Third Degree under Michigan law constituted a “violent felony for purposes of the Armed Career Criminal Act, 18 U.S.C. § 924(e). The ACCA imposes a mandatory fifteen-year prison term upon any convicted felon with three or more prior “violent felony” convictions. In Taylor v. United States, the Supreme Court held that as used in the ACCA, the word "burglary" referred to the generic way in which the term was used in most States’ criminal codes. This generic definition of burglary includes any crime that has the basic elements of unlawful or unprivileged entry into a building with the intent to commit a crime. A court must use a categorical approach focusing only on whether the elements of the crime sufficiently match those of generic burglary rather than focusing on the particular facts of the case. The district court concluded that Petitioner’s conviction constituted generic burglary under the ACCA and sentenced him to 204 months’ imprisonment. The court of appeals affirmed holding that a prior conviction may serve as a predicate to ACCA if the defendant developed the required intent to commit a crime at any point while in the building. Petitioner asks the Supreme Court to resolve an entrenched Circuit split with the Fourth, Ninth and Tenth Circuits in line with the Sixth Circuit decision, and the Fifth and Eighth Circuits requiring criminal intent at the time of unlawful entry. Petitioner argues that Taylor’s definition of generic burglary requires contemporaneous intent.

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