Wooden v. United States -- SCOTUS

In Wooden, The court explores the meaning of the word "occasion" used in the Armed Career Criminal Act. The case may have some relevance when deciding Quiroz type questions while litigating unreasonable multiplication claims (or cumulative convictions claims in international criminal law). Justices Sotomayor, Kavanaugh, and Barrett with Thomas, and Gorsuch joined by Sotomayor wrote separately to concur.

Prof. Doug Berman's take here.
Volokh Conspiracy's take is here.

The Courts of Appeals have divided over the meaning of ACCA’s “occasions” clause. Some Circuits, like the Sixth, deem the clause satisfied whenever crimes take place at different moments in time—that is, sequentially rather than simultaneously. Other Circuits undertake a more holistic inquiry, considering not merely the precise timing but also other circumstances of the crimes. We granted certiorari, 592 U. S. ___ (2021), to resolve that split of authority.

[The government argued that ten burglaries happening sequentially are ten offenses. ]

We think not. The ordinary meaning of the word “occasion”—essentially an episode or event—refutes the Government’s single-minded focus on whether a crime’s elements were established at a discrete moment in time. And ACCA’s history and purpose do so too: The origin of the “occasions” clause confirms that multiple crimes may occur on one occasion even if not at the same moment. Wooden’s night of crime is a perfect case in point. His one-after-another-after another burglary of ten units in a single storage facility occurred on one “occasion,” under a natural construction of that term and consistent with the reason it became part of ACCA.