United States v. Lockett, No. 14-15084 (11th Cir. 2016)
Annotate this CaseDefendant appealed his sentence under the three-strikes statute pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The district court counted defendant's two earlier South Carolina burglary convictions using the definition in the ACCA’s “enumerated clause,” which covers any “burglary” that is “punishable by imprisonment for a term exceeding one year.” The court concluded that the district court erred in doing so because the enumerated clause does not cover state burglary offenses whose elements are broader than the generic definition of burglary. In this case, South Carolina’s burglary offense is broader than generic burglary and does not divide into multiple, alternative offenses. Therefore, federal sentencing courts cannot know if someone convicted of South Carolina burglary was convicted of generic burglary. Accordingly, the court reversed the sentence.
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