No. 24-6396

Ryan Perrin v. United States

Lower Court: Eleventh Circuit
Docketed: 2025-01-27
Status: Denied
Type: IFP
IFP
Tags: armed-career-criminal-act categorical-approach criminal-procedure prior-conviction sentencing-enhancement state-court-decisions
Latest Conference: 2025-05-02
Question Presented (from Petition)

I. When applying the categorical approach to determine whether a prior state conviction qualifies as a predicate for the Armed Career Criminal Act (ACCA) enhancement, should courts consult authoritative state court decisions pre-dating the defendant's prior conviction (as several circuits hold), or only the most recent state court decision, even if that decision changes the conduct necessary to satisfy the offense elements (as the Eleventh Circuit holds)?

II. In Erlinger v. United States, 602 U.S. 821 (2024), this Court held that the Fifth and Sixth Amendments require the government to prove ACCA's complex different-occasions requirement to a jury beyond a reasonable doubt. Is Erlinger error structural?

III. Erlinger also explained that sentencing courts cannot use information from Shepard documents to decide if a defendant committed his prior offenses on different occasions. Can appellate courts rely on that same prohibited information to affirm an ACCA sentence imposed in violation of Erlinger?

Question Presented (AI Summary)

When applying the categorical approach to determine whether a prior state conviction qualifies as a predicate for the Armed Career Criminal Act (ACCA) enhancement, should courts consult authoritative state court decisions pre-dating the defendant's prior conviction or only the most recent state court decision?

Docket Entries

2025-05-05
Petition DENIED.
2025-04-17
DISTRIBUTED for Conference of 5/2/2025.
2025-04-08
Reply of Ryan Perrin submitted.
2025-04-08
Reply of petitioner Ryan Perrin filed.
2025-03-28
Brief of United States in opposition submitted.
2025-03-28
Brief of respondent United States in opposition filed.
2025-03-11
Supplemental Brief of Ryan Perrin submitted.
2025-03-11
Supplemental brief of petitioner Ryan Perrin filed.
2025-02-21
Motion to extend the time to file a response is granted and the time is extended to and including March 28, 2025.
2025-02-19
Motion of United States for an extension of time submitted.
2025-02-19
Motion to extend the time to file a response from February 26, 2025 to March 28, 2025, submitted to The Clerk.
2025-01-23
Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due February 26, 2025)

Attorneys

Ryan Perrin
Katherine HowardOffice of the Federal Defender, Petitioner
United States
D. John SauerSolicitor General, Respondent
Sarah M. HarrisActing Solicitor General, Respondent