Erlinger v. United States

Paul Erlinger pleaded guilty to illegal possession of a firearm as a felon. The Armed Career Criminal Act (ACCA) imposes a 15-year mandatory minimum if a defendant has three prior violent felony or serious drug convictions committed on different occasions. The district court, applying a preponderance-of-evidence standard, found that Erlinger's prior burglary convictions occurred on separate occasions and imposed the ACCA enhancement. The Seventh Circuit affirmed. The Supreme Court reversed, holding that when a factual finding about prior offenses being committed on different occasions increases the statutory mandatory minimum, the Fifth and Sixth Amendments require that a jury make that determination beyond a reasonable doubt, not a judge by a preponderance. The decision extends the Apprendi/Alleyne line of cases.

The Supreme Court reversed and remanded, holding 7-2 that the different-occasions determination must be made by a jury beyond a reasonable doubt when it increases the statutory mandatory minimum sentence.

Whether the Fifth and Sixth Amendments require a jury, rather than a judge, to decide beyond a reasonable doubt that prior offenses were committed on different occasions for purposes of an ACCA sentencing enhancement that raises the mandatory minimum.

Reinforces constitutional jury trial protections in sentencing, limits judicial fact-finding under the Armed Career Criminal Act, and affects federal sentencing procedures for recidivist enhancements. It signals continued application of Apprendi and Alleyne to factual predicates for mandatory minimums.