Wooden v. United States

In Wooden v. United States, the U.S. Supreme Court examined whether ten burglaries committed by William Dale Wooden in a single night at a storage facility constituted one criminal "occasion" or multiple occasions under the Armed Career Criminal Act. In 1997, Wooden broke into a storage facility and burglarized ten separate storage units. Years later, he was convicted of being a felon in possession of a firearm. Federal prosecutors sought an enhanced mandatory minimum sentence under the ACCA, arguing the ten prior burglary convictions occurred on different occasions. The Court unanimously reversed the Sixth Circuit, holding that Wooden's offenses occurred on a single occasion because they resulted from one uninterrupted criminal episode at the same location on the same night.

The Supreme Court ruled 9-0 in favor of Wooden, holding that the ten burglary convictions arose from a single criminal episode and counted as only one prior offense under the ACCA. The Court reasoned that the burglaries occurred at the same time, in the same location, and as part of a single uninterrupted course of conduct.

The central dispute focused on the interpretation of the ACCA's "occasions different from one another" clause, specifically whether Wooden's ten burglaries of separate storage units during a single night constituted offenses committed on different occasions, thereby triggering the statute's mandatory minimum sentencing enhancement for armed career criminals with three or more prior serious drug or violent felony convictions.

This unanimous decision clarified the scope of the ACCA's sentencing enhancement and reinforced the principle that courts should apply a holistic, common-sense approach rather than a rigid temporal test when determining whether multiple offenses occurred on different occasions. The ruling narrowed the application of mandatory minimum sentences under the ACCA, signaling judicial restraint in imposing draconian penalties where criminal conduct reflects a single episode rather than distinct recidivist behavior.