United States v. Stitt

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Supreme Court of the United States
United States v. Stitt
Term: 2018
Important Dates
Argument: October 4, 2017
Decided: December 10, 2018
Outcome
Sixth Circuit Court reversed and remanded
Vote
9-0 to reverse and remand
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh

United States v. Stitt is a case argued during the 2018-2019 term of the U.S. Supreme Court. Argument in the case was held on October 4, 2018. The court reversed the ruling of the United States Court of Appeals for the 6th Circuit, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."[1][2] The case came on a writ of certiorari to the Sixth Circuit. The court consolidated arguments in the case with arguments in U.S. v. Sims.

HIGHLIGHTS
  • The case: Victor Stitt was found guilty of possessing a firearm as a convicted felon. Because Stitt had nine prior convictions, he was sentenced under the Armed Career Criminal Act (ACCA). The ACCA applies to felons who possess a firearm and “who also have at least three prior convictions for a violent felony or serious drug offense.” Stitt argued that his prior convictions should not be considered violent felonies, and, therefore, he should not have been subjected to sentencing under the ACCA. The United States Court of Appeals for the 6th Circuit "held that a conviction for Tennessee aggravated burglary does not qualify as an ACCA violent felony.”[3]
  • The issue: Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as “burglary” under the Armed Career Criminal Act of 1984, 18 U.S.C. § 924(e)(2)(B)(ii).[4]
  • The outcome: The court reversed, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • December 10, 2018: The court reversed the ruling of the Sixth Circuit Court and remanded the case
    • October 9, 2018: Oral argument
    • April 23, 2018: U.S. Supreme Court agreed to hear case; consolidated with U.S. v. Sims
    • November 21, 2017: Petition filed with U.S. Supreme Court
    • April 27, 2017: Sixth Circuit vacated Stitt’s sentence and remanded for resentencing

    Background

    Victor Stitt was found guilty of possessing a firearm as a convicted felon for attempting to put “a loaded handgun into his girlfriend’s mouth” and threatening to kill her. Because Stitt had nine prior convictions, he was sentenced under the Armed Career Criminal Act (ACCA). The ACCA applies to felons who possess a firearm and “who also have at least three prior convictions for a violent felony or serious drug offense.”[5][3]

    Stitt argued that his prior convictions should not be considered violent felonies, and therefore he should not have been subjected to sentencing under the ACCA. According to Oyez, the United States Court of Appeals for the 6th Circuit “has held that Tennessee aggravated burglary is a violent felony under the ACCA, so a panel of that court affirmed the sentence. Sitting en banc, the Sixth Circuit overturned its precedent and held that a conviction for Tennessee aggravated burglary does not qualify as an ACCA violent felony.”[3]

    Questions presented

    The petitioner presented the following question to the court:[6]

    Question presented:
    • Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as "burglary" under the Armed Career Criminal Act of 1984, 18 U.S.C. 924(e)(2)(B)(ii).

    Audio

    • Audio of oral argument:[7]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Stephen Breyer delivered the unanimous opinion of the court. The court reversed the ruling of the Sixth Circuit Court, holding that "the term 'burglary' in the Armed Career Criminal Act includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation."[2]

    Opinion

    In his opinion for the court, Justice Breyer explained that vehicles are within the scope of structures. He wrote,

    “ The relevant language of the Tennessee and Arkansas statutes falls within the scope of generic burglary’s definition as set forth in Taylor. For one thing, we made clear in Taylor that Congress intended the definition of 'burglary' to reflect 'the generic sense in which the term [was] used in the criminal codes of most States' at the time the Act was passed. Ibid. In 1986, a majority of state burglary statutes covered vehicles adapted or customarily used for lodging—either explicitly or by defining 'building' or 'structure' to include those vehicles.[8] ”

    Transcript of opinion

    • Read the opinion transcript here.

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "U.S. v. Stitt," accessed September 20, 2018
    2. ↑ 2.0 2.1 2.2 Supreme Court of the United States, "United States v. Stitt" Opinion December 10, 2018
    3. ↑ 3.0 3.1 3.2 Oyez, United States v. Stitt, accessed September 21, 2018
    4. ↑ 4.0 4.1 SCOTUSblog, "U.S. v. Stitt," accessed September 20, 2018 Cite error: Invalid <ref> tag; name "sbstitt" defined multiple times with different content
    5. ↑ United States Court of Appeals for the 8th Circuit, "U.S. v. Sims," April 27, 2017
    6. ↑ Supreme Court of the United States, "17-765 U.S. v. Stitt," accessed September 20, 2018
    7. ↑ Supreme Court of the United States, United States v. Stitt, argued October 9, 2018
    8. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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