Facts
Taylor pleaded guilty to being a felon in possession of a firearm in the United States District Court for the Eastern District of Missouri, in violation of 18 U.S.C. § 922(g). At the time, Taylor had four prior convictions—one for robbery, one for assault, and two were for second-degree burglary under Missouri law. The government sought the sentence enhancement under 18 U.S.C. § 924(e):
(1) In the case of a person who violates section 922(g)... and has three previous convictions by any court... for a violent felony or a serious drug offense, or both... such person shall be fined not more than $25,000 and imprisoned not less than fifteen years.
(2) As used in this subsection —
- (B) the term "violent felony" means any crime punishable by imprisonment for a term exceeding one year that —
- (i) has as an element the use, attempted use, or threatened use of physical force against the person of another, or
- (ii) is burglary, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious potential risk of physical injury to another.
- (i) has as an element the use, attempted use, or threatened use of physical force against the person of another, or
Taylor conceded that his prior assault and arson convictions qualified for the § 924(e) sentencing enhancement, but disputed that his two burglary convictions qualified for the enhancement, because they did not present a serious risk of physical injury to another. The district court rejected this argument, and sentenced Taylor to 15 years without parole.
The United States Court of Appeals for the Eighth Circuit affirmed the sentence. It ruled that "burglary" "means burglary however a state chooses to define it," the district court properly counted both of Taylor's Missouri burglary convictions under the § 924(e) sentence enhancement. The U.S. Supreme Court agreed to review the case so that it could resolve a conflict among the federal courts of appeals about how "burglary" should be defined under § 924(e).
Read more about this topic: Taylor V. United States (1990)
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