United States v. Glispie, No. 19-1224 (7th Cir. 2019)
Annotate this CaseGlispie pleaded guilty as a felon in possession of a firearm, 18 U.S.C. 922(g), reserving the right to challenge his anticipated designation as an armed career criminal based on his prior Illinois convictions for residential burglary. The district court concluded that residential burglary in Illinois is no broader than “generic burglary” and that it qualified as a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(2)(B)(ii); it sentenced Glispie to 180 months. The court cited the Seventh Circuit’s 2016 “Dawkins” decision. The Seventh Circuit certified a question to the Supreme Court of Illinois: whether the limited-authority doctrine applies to the Illinois residential burglary statute. Under that doctrine, one who enters a public building with the intent to commit a crime automatically satisfies the unlawful entry requirement of the Illinois burglary statute with respect to a business burglary. If the doctrine applies to residential burglary, then a conviction for Illinois residential burglary is broader than generic burglary and cannot qualify as an aggravated felony for purposes of the ACCA.
The court issued a subsequent related opinion or order on October 14, 2020.
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