Longer sentences for past crimes
Matthew Robert Descamps v. United States
In brief
The Supreme Court overturned the Ninth Circuit and said old case records could not be used to match Descamps’s California burglary conviction to the ACCA’s burglary definition because state law had one set of required crime elements.
- Where it stands
- Decided
Decided 8-1 · June 20, 2013 · Opinion by Justice Kagan
- What it’s about
- The Supreme Court overturned the Ninth Circuit’s ruling that Matthew Descamps’s California burglary conviction could support an Armed Career Criminal Act sentence enhancement.
- Who it affects
- The ruling bars courts from using old case records to count Descamps’s California burglary conviction as qualifying under the ACCA through that review method.
Summary: written with AI from the case record.
What it's about
It ruled that courts cannot examine old case records to see whether a conviction fits standard burglary when state law defines burglary through one broad set of elements.
Descamps was convicted of possessing a firearm as a felon. A trial judge increased his sentence based partly on an earlier California burglary conviction.
The Armed Career Criminal Act can increase a sentence based on certain qualifying prior convictions.
Question presented
Did the United States properly plead and prove the defendant's prior violent felony convictions for application of an enhanced sentence under the Armed Career Criminal Act?
What the Court decided
Holding
The modified categorical approach does not apply to statutes like §459 that contain a single, indivisible set of elements. Pp. 5 − 23. 563, reversed.
- Result
- Reversed
The Court's reasoning
The Court treated California’s burglary law as setting one set of required parts for the crime, not alternative versions. With no alternative sets of parts to sort among, judges could not use old case records to decide whether Descamps’s conviction matched the ACCA’s burglary definition.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Majority · 7joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Thomaswrote separately
- Dissenting · 1disagreed with the result
- Alitowrote the dissent
From the opinions
“When it is clear that a defendant necessarily admitted or the jury necessarily found that the defendant committed the elements of generic burglary, the conviction should qualify.”
What's next
Lower courts must follow this rule when deciding whether prior convictions under laws with one set of required elements qualify under the ACCA. The opinion does not state what further step followed in Descamps’s sentencing case.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Impact Analysis
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
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Audio Recording added: Oral Arguments - Descamps
Opinion added: Descamps
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.