## Facts

- Richard Mathis pleaded guilty in federal court to being a felon in possession of a firearm.
- The government sought an enhanced 15-year mandatory minimum sentence under the Armed Career Criminal Act (ACCA) based on Mathis’s five prior Iowa burglary convictions.
- ACCA lists “burglary” as an enumerated “violent felony,” and generic burglary requires unlawful entry into a “building or other structure.”
- Iowa’s burglary statute covered unlawful entry into an “occupied structure,” including “any building, structure, [or] land, water, or air vehicle.”
- The district court treated Mathis’s Iowa burglaries as ACCA predicate “burglaries,” applied a modified categorical approach, and imposed the 15-year minimum.
- The Eighth Circuit affirmed, concluding the statute’s listed locations were alternative ways of satisfying a single element and that record materials could show Mathis burglarized buildings.

## Issues

1. Whether a conviction under a state burglary statute whose elements cover more conduct than generic burglary can qualify as ACCA “burglary.”
2. Whether a sentencing court may use the modified categorical approach to consult record documents when a statute lists alternative factual means rather than alternative elements.

## Decision

- The Supreme Court reversed the Eighth Circuit.
- Because Iowa burglary’s elements are broader than generic burglary, Mathis’s Iowa burglary convictions could not serve as ACCA predicate burglaries.
- The Court held the modified categorical approach was unavailable because the Iowa statute set out alternative means of satisfying a single element, not alternative elements defining separate crimes.

## Legal Principles

- Under ACCA’s enumerated-offense clause, courts apply the categorical approach: compare the elements of the prior offense to the elements of the generic offense, without considering the defendant’s particular conduct.
- A prior conviction does not qualify if the statute of conviction’s elements are broader than the generic offense, even if the defendant’s real-world conduct fits within the generic definition.
- The modified categorical approach applies only to divisible statutes that list alternative elements creating multiple crimes; it permits consulting a limited set of record documents solely to identify which elements formed the basis of conviction.
- When statutory alternatives are merely alternative means of satisfying a single element—so jurors need not agree on which alternative occurred—courts may not consult record documents to narrow the conviction for ACCA purposes.
- Expanding judicial factfinding beyond elements to impose ACCA’s increased penalty raises serious Sixth Amendment concerns.

## Conclusion

The Court held that ACCA’s burglary enhancement turns on an elements-only comparison to generic burglary; because Iowa burglary covers locations beyond buildings or structures and lists them as alternative means, Mathis’s prior convictions could not support the ACCA mandatory minimum.


Mathis v. United States, 579 U.S. 500 (2016)