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17-765 UNITED STATES V. STITT DECISION BELOW: 860 F.3d 854 CONSOLIDATED WITH 17-766 FOR ONE HOUR ORAL ARGUMENT. CERT. GRANTED 4/23/2018 QUESTION PRESENTED: Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as "burglary" under the Armed Career Criminal Act of 1984, 18 U.S.C. 924(e)(2)(B)(ii). LOWER COURT CASE NUMBER: 14-6158
The United States v. Stitt case in 2018 revolved around the interpretation of a clause under the Armed Career Criminal Act (ACCA). The ACCA mandates a 15-year minimum sentence for individuals convicted of possessing firearms if they have three or more previous convictions for serious drug offenses or violent felonies. Victor J. Stitt and Jason Daniel Sims, both with prior burglary convictions, argued that their crimes did not qualify as "violent felonies" because they involved vehicles adapted or used for overnight accommodation rather than traditional buildings. However, the Supreme Court unanimously ruled against them stating that such vehicles fall within ACCA's definition of "generic burglary." This ruling clarified that state law burglaries involving any kind of structure designed to house people overnight can be considered violent felonies under federal law.
In the case of United States v. Stitt, there was no dissenting opinion recorded as the Supreme Court ruled unanimously (9-0) in favor of the government's interpretation. The court held that a vehicle adapted for overnight accommodation can be considered a "building or structure" under Tennessee law and thus falls within the scope of “burglary” in Armed Career Criminal Act’s definitions. Therefore, Victor Jerald Stitt and Jason Daniel Sims' prior convictions were correctly counted as violent felonies to justify their enhanced sentences under ACCA.