Plain-English summary
Court requires unanimous jury, proof beyond reasonable doubt that prior crimes were on different occasions for ACCA
In Erlinger v. United States (23-370), the Supreme Court held that the Fifth and Sixth Amendments require a unanimous jury, beyond a reasonable doubt, to find that a defendant’s prior convictions occurred on separate occasions before the Armed Career Criminal Act's enhanced sentence can apply. The Court vacated and remanded the Seventh Circuit judgment.
Why this matters
This decision protects defendants’ constitutional trial rights in cases that trigger sentence enhancements under ACCA. It limits judges’ ability to make disputed factual findings about a defendant’s criminal history that raise the statutory penalty and ensures those facts must be found by a unanimous jury beyond a reasonable doubt.
Who may feel it
- People facing ACCA-enhanced federal sentences
- Defendants with multiple prior convictions in federal criminal cases
- Defense attorneys and federal prosecutors handling sentence-enhancement issues
- Federal courts that impose ACCA enhancements
Key questions
- Does the Constitution require a jury trial and proof beyond a reasonable doubt to find that prior convictions were "committed on occasions different from one another" for ACCA?