Erlinger v. United States

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Supreme Court of the United States
Erlinger v. United States
Term: 2023
Important Dates
Argued: March 27, 2024
Decided: June 21, 2024
Outcome
vacated and remanded
Vote
6-3
Majority
Neil Gorsuch • Chief Justice John Roberts • Clarence Thomas • Sonia Sotomayor • Elena Kagan • Amy Coney Barrett
Concurring
Chief Justice John Roberts • Clarence Thomas
Dissenting
Brett Kavanaugh • Samuel Alito • Ketanji Brown Jackson

Erlinger v. United States is a case that was decided by the Supreme Court of the United States on June 21, 2024, during the court's October 2023-2024 term. The case was argued before the Court on March 27, 2024.

In a 6-3 ruling, the Court vacated the United States Court of Appeals for the Seventh Circuit's judgment and remanded the case for further proceedings, holding, "The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes."[1] Justice Neil Gorsuch authored the majority opinion of the Court. Chief Justice John Roberts and Justice Clarence Thomas filed concurring opinions. Justice Brett Kavanaugh filed a dissenting opinion, joined by Justice Samuel Alito and by Justice Ketanji Brown Jackson, except for Part III. Justice Jackson also filed a dissenting opinion. Click here for more information about the ruling.


HIGHLIGHTS
  • The issue: The case concerned the Armed Career Criminal Act. Click here to learn more about the case's background.
  • The questions presented: "Whether the Constitution requires a jury trial and proof beyond a reasonable doubt to find that a defendant's prior convictions were "committed on occasions different from one another," as is necessary to impose an enhanced sentence under the Armed Career Criminal Act, 18 U.S.C. § 924(e)(1)"[2]
  • The outcome: The U.S. Supreme Court vacated the United States Court of Appeals for the Seventh Circuit's judgment and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Seventh Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 2018, Paul Erlinger, the petitioner, pleaded guilty to illegally possessing firearms and received a fifteen-year prison sentence. The United States District Court for the Southern District of Indiana applied the Armed Career Criminal Act (ACCA) sentencing guidelines due to Erlinger's three prior burglary convictions.[3][4][5][6]

    Erlinger has objected to the ACCA classification of his case. He argues that the definition of burglary in the federal statute does not match Indiana's definition, making the ACCA guidelines for his sentencing non-applicable.[5] The United States Court of Appeals for the Seventh Circuit determined that Indiana's definition was not broader than the federal definition.[3][6]

    Additionally, Erlinger contended that the burglaries did not occur on separate occasions. He argues that the Sixth Amendment and the Wooden v. United States decision require a jury, rather than a judge, to determine when the events resulting in his prior convictions occurred.[5] The Seventh Circuit disagreed and determined that the government was not obligated to demonstrate that the burglaries occurred on separate occasions to a jury, but rather to a sentencing judge.[3][6][4]

    Armed Career Criminal Act of 1984

    18 U.S.C. 924(e) states:[7]

    “ (1)In the case of a person who violates section 922(g) of this title and has three previous convictions by any court referred to in section 922(g)(1) of this title for a violent felony or a serious drug offense, or both, committed on occasions different from one another, such person shall be fined under this title and imprisoned not less than fifteen years, and, notwithstanding any other provision of law, the court shall not suspend the sentence of, or grant a probationary sentence to, such person with respect to the conviction under section 922(g).[8] ”

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether the Constitution requires a jury trial and proof beyond a reasonable doubt to find that a defendant's prior convictions were "committed on occasions different from one another," as is necessary to impose an enhanced sentence under the Armed Career Criminal Act, 18 U.S.C. § 924(e)(1)

    [8]

    		”

    Oral argument

    Audio

    Audio of oral argument:[9]




    Transcript

    Transcript of oral argument:[10]

    Outcome

    In a 6-3 ruling, the Court vacated the United States Court of Appeals for the Seventh Circuit's judgment and remanded the case for further proceedings, holding, "The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes."[1] Justice Neil Gorsuch authored the majority opinion of the Court. Chief Justice John Roberts and Justice Clarence Thomas filed concurring opinions. Justice Brett Kavanaugh filed a dissenting opinion, joined by Justice Samuel Alito and by Justice Ketanji Brown Jackson, except for Part III. Justice Jackson also filed a dissenting opinion.


    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[1]

    “ This case concerns the Armed Career Criminal Act (ACCA) and the Fifth and Sixth Amendments. ACCA imposes lengthy mandatory prison terms on certain defendants who have previously committed three violent felonies or serious drug offenses on separate occasions. The question we face is whether a judge may decide that a defendant’s past offenses were committed on separate occasions under a preponderance-of-the-evidence standard, or whether the Fifth and Sixth Amendments require a unanimous jury to make that determination beyond a reasonable doubt.


    ... The jury trial may have “never been efficient.” Apprendi, 530 U. S., at 498 (Scalia, J., concurring). It may require assembling a group of the defendant’s peers to resolve unanimously even seemingly straightforward factual questions under a daunting reasonable doubt standard. Avoiding the prejudice associated with the introduction of evidence of past crimes may require careful attention, too. But the right to a jury trial “has always been” an important part of what keeps this Nation “free.” Ibid. Because the Fifth and Sixth Amendments do not tolerate the denial of that right in this case, the judgment of the Court of Appeals for the Seventh Circuit is vacated, and the matter is remanded for further proceedings consistent with this opinion.[8]

    		”
    —Justice Neil Gorsuch

    Concurring opinions

    Chief Justice Roberts

    Chief Justice John Roberts filed a concurring opinion.

    In his concurring opinion, Chief Justice Roberts wrote:[1]

    “ I join the opinion of the Court because I agree that under the Fifth and Sixth Amendments, a defendant is entitled to have a jury determine beyond a reasonable doubt whether his predicate offenses were committed on different occasions for purposes of the Armed Career Criminal Act. But as JUSTICE KAVANAUGH explains, violations of that right are subject to harmless error review. See post, at 9–11 (dissenting opinion). The Seventh Circuit should thus consider on remand the Government’s contention that the error here was harmless.[8] ”
    —Chief Justice John Roberts


    Justice Thomas

    Justice Clarence Thomas filed a concurring opinion.

    In his concurring opinion, Justice Thomas wrote:[1]

    “ I join the Court’s opinion in full because it correctly applies our precedents. ...


    ... I continue to adhere to my view that we should revisit Almendarez-Torres and correct the “error to which I succumbed” by joining that decision.

    We need not overrule Almendarez-Torres to rule in Erlinger’s favor, and he did not ask us to reconsider the decision—although he agrees that it should be overruled. Tr. of Oral Arg. 5. But, we have no shortage of other cases. Each Term, criminal defendants file a flood of petitions “specifically presenting this Court with opportunities to reconsider Almendarez-Torres.” Rangel-Reyes, 547 U. S., at 1202 (opinion of THOMAS, J.). Today’s decision demonstrates further that “[i]t is time for this Court to do its part” by granting one of those many petitions and overruling Almendarez-Torres. Rangel-Reyes, 547 U. S., at 1202.[8]

    		”
    —Justice Clarence Thomas


    Dissenting opinions

    Justice Kavanaugh

    Justice Brett Kavanaugh filed a dissenting opinion, joined by Justice Samuel Alito and by Justice Ketanji Brown Jackson, except for Part III.

    In his dissent, Justice Kavanaugh wrote:[1]

    “ As relevant here, ACCA imposes a minimum sentence on a defendant who previously was convicted of at least three violent felonies committed on different occasions—and who then, after the three prior violent felony convictions, unlawfully possessed a firearm. In applying ACCA’s minimum sentencing requirement, the Sixth Amendment allows a judge to determine whether the defendant has three or more prior convictions and whether those convictions were for violent felonies. The question in this case is whether the judge may also determine whether the defendant committed those prior crimes on different occasions, or instead whether a jury must do so.


    In my view, this Court’s precedents establish that a judge may make the different-occasions determination. Because the Court today concludes that only a jury may make the different-occasions determination, I respectfully dissent.[8]

    		”
    —Justice Brett Kavanaugh


    Justice Jackson

    Justice Ketanji Brown Jackson filed a dissenting opinion.

    In her dissent, Justice Jackson wrote:[1]

    “ In the Armed Career Criminal Act (ACCA), 18 U. S. C.§924(e), Congress directed sentencing judges to conduct a “multi-factored” inquiry into “a range of circumstances” to determine whether a particular defendant’s criminal history suggests that he is the sort of “ ‘revolving door’ felo[n]” that ACCA was designed to target. Wooden v. United States, 595 U. S. 360, 369, 375 (2022); see also §924(e)(1). Those kinds of findings have historically been deemed well within the capacity of a sentencing judge. See Almendarez-Torres v. United States, 523 U. S. 224, 243–244 (1998). To-day, the Court concludes that Apprendi v. New Jersey, 530U. S. 466 (2000), must be read to suggest otherwise—i.e.,that under Apprendi, for sentencing purposes, facts that relate to a defendant’s prior crimes cannot be determined by judges but instead must be found by juries. I disagree for several reasons, including my overarching view that Apprendi was wrongly decided. Like many jurists and other observers before me, I do not believe that Congress exceeds its constitutional authority when it empowers judges to make factual determinations related to punishment and directs that a particular sentencing result follow from such findings.


    I recognize, of course, that Apprendi is a binding precedent of this Court, and one that “has now defined the relevant legal regime” for nearly a quarter century. ... But considering the flaws inherent in Apprendi’s approach, I cannot join today’s effort to further extend Apprendi’s holding, particularly when there is a well-established recidivism exception to the Apprendi rule that applies to the circumstances of the case before us now.

    I agree with JUSTICE KAVANAUGH that, all things considered, the Court errs in concluding today that ACCA’s occasions inquiry must be decided by a jury. See ante, at 3–9 (dissenting opinion). I write separately to provide an additional critical perspective on the Apprendi doctrine—one that is informed by how sentencing has actually worked onthe ground, before and after Apprendi—and to note that applying the Apprendi rule to ACCA’s occasions finding creates all sorts of practical problems that are easily avoided by simply allowing judges to do what they have always done. Because the Court pushes the flawed Apprendi rule past where it needs to go, and, incidentally, establishes a procedural requirement that is likely impossible to implement in real life, I respectfully dissent.[8]

    		”
    —Justice Ketanji Brown Jackson


    Text of the opinion

    Read the full opinion here.


    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[11]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, Erlinger v. United States, decided June 21, 2024
    2. ↑ 2.0 2.1 Supreme Court of the United States "23-370 ERLINGER V. UNITED STATES: Questions presented," accessed November 27, 2023
    3. ↑ 3.0 3.1 3.2 Oyez "Erlinger v. United States," November 20, 2023
    4. ↑ 4.0 4.1 Supreme Court of the United States "Erlinger v. United States, BRIEF FOR RESPONDENT SUPPORTING PETITIONER," January 3, 2024
    5. ↑ 5.0 5.1 5.2 Supreme Court of the United States "Erlinger v. United States, BRIEF FOR PETITIONER," January 3, 2024
    6. ↑ 6.0 6.1 6.2 United States District Court for the Southern District of Indiana "United States v. Erlinger," August 10, 2023
    7. ↑ Cornell Law School "18 U.S. Code § 924 - Penalties," accessed February 21, 2024
    8. ↑ 8.0 8.1 8.2 8.3 8.4 8.5 8.6 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    9. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 27, 2024
    10. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 27, 2024
    11. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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