Plain-English summary
Reverses Sixth Circuit on warrantless home entry and narrows ACCA 'occasions' reading in Wooden v. United
The Court reversed the Sixth Circuit. It held that the warrantless entry and search of William Wooden's home violated the Fourth Amendment, and it limited the Sixth Circuit’s approach to the phrase "committed on occasions different" in the Armed Career Criminal Act (ACCA). The decision narrows how repeated offenses are counted for enhanced sentences.
Why this matters
The decision protects homeowners from certain warrantless law-enforcement entries and clarifies limits on counting prior convictions for harsher federal sentences under the ACCA. That affects how courts assess whether repeat offenses qualify a defendant for an enhanced mandatory minimum sentence.
Who may feel it
- People charged with federal firearms offenses facing ACCA sentence enhancements
- Anyone subject to a home search by federal or state law enforcement
- Defense lawyers and prosecutors litigating prior-conviction counts for sentence enhancement
- Lower federal courts applying ACCA and Fourth Amendment rules
Key questions
- Did law enforcement’s warrantless entry and search of Wooden’s home violate the Fourth Amendment?
- Did the Sixth Circuit err by expanding the meaning of the ACCA’s phrase "committed on occasions different" without clear statutory definition, thereby counting separate convictions more broadly for sentence enhancement?