In Mathis v. United States, No. 15-6092, the Supreme Court reaffirmed the categorical approach to determining whether a prior conviction can give rise to the enhanced sentencing provisions of the ACCA. If the elements of a state crime are broader than the elements listed in the generic offense, a conviction for the state crime cannot qualify as a predicate under the ACCA. This remains true even if the defendant’s actual conduct fit within the definition of the generic offense. In Mathis, the defendant’s prior conviction for burglary did not qualify as a prior violent offense under the ACCA because the Iowa burglary statute under which he was convicted — which listed “structures” and “vehicles” as alternative means for fulfilling one of the crime’s elements — was broader than generic burglary. Even though his conduct had involved burglarizing a structure, that fact was “off-limits” to the sentencing judge.
Justice Kagan delivered the opinion of the Court, in which Roberts, Kennedy, Thomas, and Sotomayor joined. Kennedy and Thomas filed concurring opinions. Breyer, Ginsburg, and Alito dissented, with Breyer (joined by Ginsburg) and Alito writing in dissent.