| Erlinger v. United States | |
|---|---|
 | |
| Argued March 27, 2024 Decided June 21, 2024 | |
| Full case name | Paul Erlinger v. United States |
| Docket no. | 23-370 |
| Citations | 602U.S. 821 (more) 144 S.Ct. 1840, 219 L.Ed.2d 451 |
| Argument | Oral argument |
| Case history | |
| Prior | United States v. Erlinger, 77 F.4th617 (7th Cir. 2023). |
| Questions presented | |
| Whether the Constitution requires a jury trial and proof beyond a reasonable doubt to find that a defendant's prior convictions were "committed on occasions different from one another," as is necessary to impose an enhanced sentence under theArmed Career Criminal Act, 18 U.S.C. § 924(e)(1). | |
| Holding | |
| TheFifth andSixth Amendments require a unanimous jury to make the determinationbeyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions forACCA purposes. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Gorsuch, joined by Roberts, Thomas, Sotomayor, Kagan, Barrett |
| Concurrence | Roberts |
| Concurrence | Thomas |
| Dissent | Kavanaugh, joined by Alito; Jackson (except Part III) |
| Dissent | Jackson |
| Laws applied | |
| U.S. Const. amends. VI, 18 U.S.C. § 924(e)(1) | |
Erlinger v. United States, 602 U.S. 821 (2024), was aUnited States Supreme Court case relating to the right to ajury trial in criminal cases under theFifth andSixth Amendments. The case was argued on March 27, 2024, and decided on June 21.
Paul Erlinger was charged and convicted of being a felon in possession of a firearm in 2018.[1] He was sentenced to 15 years and sought post-conviction relief. The District Court found that Erlinger had committed three separate burglaries, making him eligible for theACCA enhancement.[2] Erlinger objected, arguing that the burglary question should have beenfound by a jury.[2] The Supreme Court held inApprendi v. New Jersey that:
"[o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt."
— Justice Stevens,Apprendi v. New Jersey, 530 U.S. 466, 490 (2000).[3]
TheUnited States District Court for the Southern District of Indiana overruled his objection and re-imposed the 15-year sentence.[2] Erlinger appealed to theUnited States Court of Appeals for the Seventh Circuit, which affirmed his sentence, holding that the government was only required to prove the burglary question to the judge by apreponderance of the evidence, as opposed tobeyond a reasonable doubt.[1][4] The Supreme Court grantedcertiorari on November 20, 2023.[5]
Text ofErlinger v. United States,602 U.S. ___ (2024) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (slip opinion)