Quarles v. United States
In brief
The Court ruled that intent formed while a person is unlawfully inside a building is enough for generic remaining-in burglary under the federal sentencing law.
- Where it stands
- Decided
Decided 9-0 · June 10, 2019 · Opinion by Justice Kavanaugh
- What it’s about
- The Supreme Court upheld the Sixth Circuit’s ruling for the United States, deciding that the Armed Career Criminal Act (ACCA) treats Michigan’s third-degree home-invasion law as generic burglary even when criminal intent forms after entry but while unlawfully remaining inside.
- Who it affects
- The ruling means the Michigan conviction in this case can count as burglary under a federal law that can trigger a longer prison sentence for some people convicted of possessing firearms.
Summary: written with AI from the case record.
What it's about
The decision left Jamar Quarles’s Michigan conviction eligible to support the ACCA’s longer sentence for certain repeat firearm offenders.
The case concerns how federal courts compare state crimes with the federal definition of burglary in the Armed Career Criminal Act.
Question presented
Whether (as two circuits hold) Taylor's definition of generic burglary requires proof that intent to commit a crime was present at the time of unlawful entry or first unlawful remaining, or whether (as the court below and three other circuits hold) it is enough that the defendant formed the intent to commit a crime at any time while "remaining in" the building or structure.
What the Court decided
Holding
1. Generic remaining-in burglary occurs under §924(e) when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure. In ordinary usage, “remaining-in” refers to a continuous activity, and this Court has followed that ordinary meaning in analogous legal contexts, see, e.g. , United States v. Cores , 356 U. S. 405, 408. 2. For the Court’s purposes here, the Michigan home-invasion statute substantially corresponds to or is narrower than generic burglary. The conclusion that generic remaining-in burglary occurs when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure resolves this case. When deciding whether a state law is broader than generic burglary, the state law’s “exact definition or label” does not control. Taylor, 495 U. S., at 599. So long as the state law in question “substantially corresponds” to (or is narrower than) generic burglary, the conviction qualifies. Ibid . 850 F. 3d 836, affirmed.
- Result
- Affirmed
The vote
What's next
The Supreme Court has finished this case. The Sixth Circuit’s ruling stands, and the case returns to the ordinary process for carrying out that result.
Why it matters
It also settles the timing question for “remaining-in” burglary under that law.
Documents
Docket activity
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More questions
- What did the Supreme Court decide in Quarles v. United States?
- The Court upheld the Sixth Circuit. It ruled that intent may form at any time while someone unlawfully remains inside a building.
- Why did the timing of intent matter in Quarles?
- It determined whether Quarles’s Michigan home-invasion conviction counted as burglary under the Armed Career Criminal Act. That law can lead to a longer prison sentence.
- Did Michigan home invasion qualify as generic burglary?
- Yes. The Court ruled that the Michigan law at issue substantially matched, or was narrower than, generic burglary.
- Who won Quarles v. United States?
- The United States won because the Court upheld the Sixth Circuit ruling. The Court’s decision was unanimous.
- What happens next in Quarles v. United States?
- The Supreme Court’s work is complete. The Sixth Circuit ruling remains in place for this case.
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.