Taylor v. United States

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Brief Fact Summary.

Defendant appeals a sentence enhancement when he plead guilty to possession of a firearm by a convicted felon.

Synopsis of Rule of Law.

For the purposes of sentence enhancement under 18 U.S.C. § 924(e), burglary means the unlawful or unprivileged entry into, or remaining in, a building or other structure with intent to commit a crime.

Points of Law - Legal Principles in this Case for Law Students.

The most likely explanation, in view of the legislative history, is that Congress thought that certain general categories of property crimes--namely burglary, arson, extortion, and the use of explosives--so often presented a risk of injury to persons, or were so often committed by career criminals, that they should be included in the enhancement statute even though, considered solely in terms of their statutory elements, they do not necessarily involve the use or threat of force against a person.

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Facts.

Arthur Lajuane Taylor (Defendant) pleaded guilty to possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Defendant had four prior convictions: one for robbery, one for assault, and two for second-degree burglary under Missouri law. Given these prior convictions, the prosecution sought a sentence enhancement under 18 U.S.C. § 924(e), which authorizes sentence enhancements for individuals who violate section 922(g) and who have three previous convictions for certain crimes that present a serious potential risk of physical injury to another. Defendant opposed the prosecution’s request for the sentence enhancement on the ground that his burglary convictions did not involve conduct that presented such a risk. Under the terms of his guilty plea, Defendant had a right to appeal the enhancement. Defendant exercised this right and appealed.

Issue.

Whether the term burglary is limited to the common law definition of the term for the purposes of sentence enhancement under 18 U.S.C. § 924(e).

Held.

No. The court of appeals’ ruling is vacated and the case is remanded for further proceedings. For the purposes of sentence enhancement under 18 U.S.C. § 924(e), burglary means the unlawful or unprivileged entry into, or remaining in, a building or other structure with intent to commit a crime.

Discussion.

Although the sentence enhancement provision does not expressly define burglary, the term must have a uniform definition. This definition is independent of those set forth in various states’ criminal codes and is broader than the common law definition of the term. Instead, the definition of burglary for the purposes of 18 U.S.C. § 924(e) tracks the generic, contemporary meaning of burglary that most states use. Here, the record does not contain enough information regarding Defendant’s prior burglary convictions to determine whether his conduct would fall within the meaning of burglary under section 924(e).

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