U.S. Supreme Court

Prisoner who filed pro se appeal of his enhanced sentence wins Supreme Court review

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An inmate convicted for breaking into 10 storage lockers has persuaded the U.S. Supreme Court to review his mandatory minimum sentence under the Armed Career Criminal Act.

The Supreme Court accepted William Wooden’s pro se appeal Monday, SCOTUSblog reports. Wooden submitted his cert petition on his own, although he was represented by Arnold & Porter on the reply brief.

The Supreme Court agreed to consider whether Wooden’s 10 storage locker break-ins—all committed at one facility on just one night in Georgia—were “committed on occasions different from one another.” If they were, the federal Armed Career Criminal Act kicks in, and Wooden gets an extra 15 years in prison, the reply brief explains.

The statute’s text, structure, history and purpose show that “offenses are not committed on different ‘occasions’ just because they occur sequentially,” the reply brief argued. “One night in a storage facility does not an ‘Armed Career Criminal’ make.”

The 6th U.S. Circuit Court of Appeals at Cincinnati ruled against Wooden on the issue, which exacerbated an acknowledged circuit split, the reply brief said.

SCOTUSblog has previously described the Armed Career Criminal Act as a “‘three strikes’-type sentencing enhancement.” The federal law has spawned so much litigation that “it can sometimes seem as if there are more Armed Career Criminal Act appeals than there are armed career criminals,” the blog said.

The case is Wooden v. United States. The SCOTUSblog case page is here.

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