## Facts

- Arthur Lajuane Taylor pleaded guilty in the U.S. District Court for the Eastern District of Missouri to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
- Taylor had four prior convictions, including two Missouri convictions for second-degree burglary.
- The Government sought an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), which applies to a § 922(g) offender with three prior convictions for a “violent felony” (or serious drug offense).
- ACCA lists “burglary” as a “violent felony” but does not define the term.
- The District Court applied the enhancement, rejecting Taylor’s argument that his Missouri burglary convictions did not qualify.
- The Eighth Circuit affirmed, holding that “burglary” in ACCA means burglary as defined by the convicting State.
- The Supreme Court granted certiorari to determine the meaning of “burglary” in ACCA and how sentencing courts should evaluate prior burglary convictions.

## Issues

1. Whether “burglary” in 18 U.S.C. § 924(e) adopts varying state-law definitions or instead has a uniform federal meaning.
2. What method a federal sentencing court must use to decide whether a prior state conviction counts as “burglary” under ACCA.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that “burglary” in § 924(e) is a generic federal offense, not whatever a State labels “burglary.”
- An offense qualifies as “burglary” under § 924(e) if it has the elements of “generic burglary”: unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime.
- In determining whether a prior conviction is for ACCA burglary, the sentencing court generally considers only the statutory definition and the fact of conviction.
- In a narrow category of cases where the statute of conviction is broader than generic burglary, the court may examine the charging document and jury instructions to determine whether the conviction necessarily rested on the elements of generic burglary.

## Legal Principles

- Terms in ACCA identifying predicate offenses can carry uniform, generic federal meanings rather than incorporating diverse state labels.
- “Burglary” under 18 U.S.C. § 924(e) means “generic burglary”: unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime.
- The “categorical approach” governs ACCA predicate determinations: courts look to the statutory elements of the prior offense, not the defendant’s actual conduct.
- A limited “modified categorical” inquiry is permitted when a statute is broader than generic burglary; courts may consult certain conviction documents (such as charging papers and jury instructions) to determine whether the jury necessarily found the elements of generic burglary.
- A case-by-case factual inquiry into the details of the prior offense is not permitted for ACCA burglary determinations.

## Conclusion

The Court required a uniform, generic definition of “burglary” for ACCA enhancements and mandated a categorical method focused on statutory elements, allowing limited consultation of charging documents and jury instructions only when necessary to determine whether the prior conviction necessarily matched generic burglary.


Taylor v. United States, 495 U.S. 575 (1990)