## Facts

- In 1997, William Dale Wooden and accomplices broke into a one-building mini-storage facility in Dalton, Georgia, and burglarized ten storage units by moving from unit to unit through interior walls.
- Georgia prosecuted Wooden in a single indictment charging ten burglary counts (one per unit); Wooden pleaded guilty to all ten counts.
- In 2014, Wooden was federally charged and later convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm and ammunition.
- The United States sought an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e)(1), arguing the ten burglary convictions were committed on “occasions different from one another.”
- The district court applied ACCA, treating each unit entry as a separate “occasion,” resulting in a sentence near sixteen years (exceeding the otherwise applicable ten-year maximum).
- The court of appeals affirmed, reasoning that sequential offenses at “different moments in time” satisfy ACCA’s occasions clause.

## Issues

1. Whether ten burglaries committed sequentially during a single night’s entry into one storage facility were “committed on occasions different from one another” under 18 U.S.C. § 924(e)(1).

## Decision

- The Supreme Court reversed and remanded.
- The Court held that Wooden’s ten burglaries were part of a single criminal episode and therefore occurred on one “occasion” for ACCA purposes.
- The Court rejected a rule that treats any sequentially timed offenses as separate “occasions.”

## Legal Principles

- “Occasion” in ACCA carries its ordinary meaning and can cover a span of time and a sequence of related acts, not only conduct at a single instant.
- Determining whether crimes occurred on different “occasions” requires a contextual, fact-sensitive inquiry, commonly considering:
  - temporal proximity (close in time versus separated by substantial gaps),
  - spatial proximity (same location versus significant distance),
  - the relationship and continuity of conduct (uninterrupted course versus intervening events or meaningful breaks).
- ACCA’s occasions clause targets multiple criminal episodes indicative of repeated offending over time; multiple counts arising from a single spree may count only once.

## Conclusion

Because Wooden’s burglaries occurred during one uninterrupted course of conduct at one location on a single night, they were not committed on “occasions different from one another,” and ACCA’s enhanced penalty could not be based on counting those burglaries as multiple predicate occasions.


Wooden v. United States, 595 U.S. 360 (2022)