Sentence Enhancement

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US Supreme Court

Case Name: Mathis v. United States

Case No.: 15-6092

Focus: Sentence Enhancement

Because the elements of Iowa’s burglary law are broader than those of generic burglary, Mathis’s prior convictions cannot give rise to ACCA’s sentence enhancement

“This case is resolved by this Court’s precedents, which have repeatedly held, and in no uncertain terms, that a state crime cannot qualify as an ACCA predicate if its elements are broader than those of a listed generic offense. See, e.g., Taylor, 495 U. S., at 602. The “underlying brute facts or means” by which the defendant commits his crime, Richardson v. United States, 526 U. S. 813, 817, make no difference; even if the defendant’s conduct, in fact, fits within the definition of the generic offense, the mismatch of elements saves him from an ACCA sentence. ACCA requires a sentencing judge to look only to “the elements of the [offense], not to the facts of [the] defendant’s conduct.” Taylor, 495 U. S., at 601.”

Reversed

CONCURRING: KENNEDY, THOMAS

DISSENTING: BREYER, GINSBURG, ALITO

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.