Shepard v. United States, 544 U.S. 13 (2005)

In the case of Shepard v. United States, Reginald Shepard was indicted for violating 18 U.S.C. §922(g)(1), which prohibits felons from possessing firearms. Shepard pleaded guilty to the charge, but during sentencing, the government argued that his prior convictions for burglary under Massachusetts law qualified as predicate offenses under the Armed Career Criminal Act (ACCA), which mandates a minimum 15-year sentence for individuals with three prior convictions for serious drug offenses or violent felonies. The government contended that these prior convictions constituted "generic burglary," which is defined as unlawful entry into a building or structure with intent to commit a crime. However, the District Court ruled that the ACCA's categorical approach, as established in Taylor v. United States, prevented the consideration of Shepard's prior convictions as predicates for the mandatory minimum sentence. The procedural history reveals that the case reached the Supreme Court on a writ of certiorari after the First Circuit Court of Appeals reviewed the District Court's decision. The central issue before the Supreme Court was whether a sentencing court could consider police reports or complaint applications to determine if a prior guilty plea necessarily admitted to a conviction for generic burglary. The Court ultimately held that such documents could not be used for this purpose, and that the sentencing court should limit its examination to the statutory definition of the prior offense, charging documents, written plea agreements, transcripts of plea colloquies, and any explicit factual findings by the trial judge. The background context of this case is rooted in the ACCA's definition of violent felonies, particularly the classification of burglary. The ACCA specifies that burglary must be of a building or enclosed space to qualify as a violent felony, which creates complications in jurisdictions like Massachusetts where burglary statutes may include broader definitions, such as entries into vehicles or boats. The Supreme Court's decision in this case was significant in clarifying the limitations on what evidence could be considered when determining whether a prior conviction met the criteria for generic burglary under the ACCA.

Whether a sentencing court can look to police reports or complaint applications to determine if an earlier guilty plea necessarily admitted and supported a conviction for generic burglary under the Armed Career Criminal Act (ACCA).

The judgment is reversed.