Mobile-home burglary sentencing
United States v. Stitt
In brief
The Court unanimously overturned the Sixth Circuit’s judgment in Stitt’s case.
- Where it stands
- Decided
Decided 9-0 · December 10, 2018 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court overturned the Sixth Circuit’s ruling in Victor Stitt’s case.
- Who it affects
- The Sixth Circuit’s judgment in Stitt’s case no longer stands.
Summary: written with AI from the case record.

What it's about
It decided that the Armed Career Criminal Act, a federal repeat-offender sentencing law, covers burglary of a vehicle or other structure adapted or commonly used for overnight stays.
The Armed Career Criminal Act is a federal repeat-offender sentencing law.
Question presented
Whether burglary of a nonpermanent or mobile structure that is adapted or used for overnight accommodation can qualify as "burglary" under the Armed Career Criminal Act of 1984, 18 U.S.C. 924(e)(2)(B)(ii).
What the Court decided
Holding
Sims’ case is remanded for further proceedings. His argument that Arkansas’ residential burglary statute is too broad to count as generic burglary because it also covers burglary of “a vehicle . . . [w]here any person lives,” Ark. Code Ann. §5–39–101(1)(A), rests in part upon state law, and the lower courts have not considered it. Those courts remain free to determine whether Sims properly presented that argument and, if so, to decide the merits. No. 17–765, 860 F. 3d 854, reversed
- Result
- Reversed
The vote
What's next
The Supreme Court has finished its action; the next step in Stitt’s case is not specified.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
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.