Sunday, November 17, 2013

Taylor v. United States case brief

Taylor v. United States case brief summary
495 U.S. 575


CASE SYNOPSIS
Defendant was convicted of possession of a firearm by a convicted felon in violation of 18 U.S.C.S. § 922(g)(1). He challenged a decision of the United States Court of Appeals for the Eighth Circuit, which affirmed his enhanced sentence. The Court granted certiorari.

CASE FACTS
Defendant's sentence was enhanced pursuant to 18 U.S.C.S. § 924(e), based on defendant's prior convictions, two of which were burglary. Defendant argued that his burglary convictions were not to be counted for enhancement purposes, because they did not involve conduct that presented a serious risk of personal injury to another under 18 U.S.C.S. § 924(e)(2)(B)(i).

DISCUSSION

  • The Court found that a person was convicted of burglary for purposes of sentence enhancement under § 924(e) if he was convicted of any crime, regardless of its exact definition, having the basic elements of unlawful entry. 
  • The Court found that § 924(e)required a trial court to look only to the fact of conviction and the statutory definition of the prior offense, rather than the particular facts underlying the conviction. 
  • The Court noted that, in the state in which defendant received his burglary convictions, most but not all of the burglary statutes included all the elements of generic burglary. 
  • However, because the Court could not ascertain which of those statutes were the bases for defendant's prior convictions, the Court remanded.

CONCLUSION
The Court vacated the decision that affirmed defendant's enhanced sentence and remanded.


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