Adam Longoria v. United States
JusticiabilityDoctri Jurisdiction
Whether the ACCA's 'occasions different from one another' clause requires a sentencing court to rely solely on elemental facts, or whether it can rely on non-elemental facts
QUESTION PRESENTED The Armed Career Criminal Act (ACCA) imposes a fifteen year mandatory minimum sentence for anyone who violates 18 U.S.C. § 922(g) and has three previous convictions for a “violent felony” or a “serious drug offense,” or both, “committed on occasions different from one another.” 18 U.S.C. § 924(e). This Court has held that in examining whether a prior conviction is an ACCA predicate, sentencing courts look only to the offense’s elements, and not the particular facts of a case. See Taylor v. United States, 495 U.S. 575, 600-01 (1990); Descamps v. United States, 570 U.S. 254 (2013); Mathis v. United States, 136 S. Ct. 2243, 2245 (2016). This Court has never, however, addressed whether the constitutional principles requiring that elemental analysis also apply to the “occasions different from one another” phrase in that sentence. This case presents that question: Under the ACCA, can a sentencing court rely solely on non-elemental facts to infer that a defendant’s temporally overlapping and related offenses were “committed on occasions different from one another”? i