United States v. Stitt

The U.S. Supreme Court consolidated the cases of Victor Stitt and Jason Sims, who were convicted of federal firearm offenses and received enhanced sentences under the Armed Career Criminal Act based on prior state burglary convictions. Stitt had convictions under Tennessee law for aggravated burglary, while Sims had Arkansas convictions for residential burglary. Both defendants argued that their prior offenses did not qualify as "violent felonies" under the ACCA because the state statutes covered structures like RVs, tents, and mobile homes that fell outside the generic definition of burglary. The question was whether these state laws, interpreted broadly, still fit within the federal generic burglary standard, which requires unlawful entry into a building or structure. The Supreme Court unanimously held that the scope of these statutes remained consistent with the generic offense of burglary, thus affirming the enhanced sentences.

In a unanimous decision written by Justice Stephen Breyer, the Supreme Court ruled that Tennessee's aggravated burglary statute and Arkansas's residential burglary statute fall within the scope of generic burglary under the ACCA. The Court concluded that generic burglary includes structures and vehicles adapted or customarily used for overnight accommodation, affirming the sentence enhancements for both defendants.

Whether a state burglary statute that encompasses non-traditional structures and vehicles such as tents, mobile homes, and recreational vehicles qualifies as a "violent felony" under the enumerated offenses clause of the Armed Career Criminal Act, which applies the generic definition of burglary.

The ruling provided critical uniformity in federal sentencing by clarifying the boundaries of the "violent felony" definition under the ACCA. It affirmed that a broad range of state burglary convictions involving modern living spaces count as predicate offenses, thereby upholding mandatory minimum sentences for armed career criminals and influencing the handling of numerous pending and future sentencing cases nationwide.