Mathis v. United States (15-6092)
argument 15-6092Mathis v. United States
Supreme Court of the United States
1h 1m
4 speakers
8 chapters
transcribed 5 days ago
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What is the Iowa burglary statute at issue and why does it matter in Mathis v. United States?
We'll hear argument first this morning in Case 15-6092, Mathis v. United States. Mr. Fleming.
Mr. Chief Justice, and may it please the Court, the Iowa statute under which Mr. Mathis was convicted defines one crime, and Iowa does not need to prove generic burglary to convict under it. The Eighth Circuit below and the government here, nonetheless, want to use the modified categorical approach, not for its usual purpose, which is to identify the crime of conviction. We know what that is. but rather to identify the means of commission. That is contrary to ACCA's categorical approach, and it's irreconcilable with both the result and the reasoning of this Court's decision in Des Camp. Why is that so? I mean, here we have the crime, burglary, and there are two ways of committing it. One involves a structure, one involves a vehicle, and those can be easily divided.
We look at the charge. The charge is for A structure, not for a vehicle? Why is it not divisible? For the exact same reason, Justice Ginsburg, that the California statute at issue in DeCamp was not divisible. In that case as well, the indictment charged that Mr. DeCamp had unlawfully and feloniously entered the grocery store. The prosecutor stated as much that Mr. DeCamp had broken and entered into a grocery store, and Mr. DeCamp did not object to that. Nonetheless, this Court quite properly... held that it was not divisible because California was not required to prove unlawful entry in order to get a conviction. The same is true of Mr. Mathis. Iowa did not have to prove the type of occupied structure that he supposedly
burglarized. To prove one or the other, in day camp, there was an element that didn't have to be proved under the state statute. You didn't have to prove unlawful. California would have had to prove entry. just as Iowa would have to prove an occupied structure. But California did not have to prove whether the entry was unlawful, as would have been required to make the offense a generic burglary offense. Similarly here, Iowa did not need to prove burglary of a building as opposed to burglary of a land, air, or water vehicle or similar place. Those are issues that there's no dispute. A jury could have divided on, or Mr. Mathis would not have had to admit specifically in order to permit a conviction under the Iowa statute.
But they have to prove one of the – they define somewhere a structure, right, in the statute? They do, Justice Breyer. And don't you have to prove that that definition applies? I mean, you know, suppose it was a structure for an animal at a zoo or something. I mean, that wouldn't count, would it?
It might not, but there
has to be... All right. Well, if it does not, don't you have to at least prove that it falls within the definition? The definition of occupied structure? Yes, Your Honor. Okay. And similarly in Taylor, you have to prove that it falls within the statute's definition of boat or car or house, right? You have to prove one of the three. That is the difference. But you don't have to prove... You have to prove in Massachusetts... if you have an indictment which says it was like a houseboat, so they're not certain what it counts as. So they say, don't you have to prove our prosecutor says it's a boat or a house. Now, would that get a conviction in Massachusetts? They prove that it's either a boat or a house. Do they get a conviction or not?
This court in Shepard assumed
that
we don't know Massachusetts law. I'm saying under Massachusetts law, would you be able to convict the person?
This court assumed because it wasn't disputed in Shepard that the answer is no. The
answer is no? You cannot convict a person, say, on a houseboat in Massachusetts where the prosecutor says it's either a house or a boat. They have to go into what the difference is?
As this court interpreted it in Shepard, house or boat are elements of the crime.
So, in other words, if six people think a houseboat is a boat and six people think a houseboat is a house, the guy gets off.
In
Massachusetts. You got
any case on that? I'd be rather surprised.
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Chapters
8 chapters
1
What is the Iowa burglary statute at issue and why does it matter in Mathis v. United States?
0:00–5:59
2
How does the Court distinguish between an “element” and a “means” under the modified categorical approach?
5:59–13:05
3
Why does the government argue that the statute’s disjunctive language requires a means‑based analysis?
13:05–20:06
4
What precedent does the Court rely on from DeCamp and Des Camp to decide divisibility?
20:06–28:23
5
How do Shepard documents help determine whether a conviction matches the generic burglary offense?
28:23–36:26
6
Why does the petitioners’ approach risk creating a Sixth Amendment problem for sentencing courts?
36:26–44:46
7
What would be the effect of treating statutory alternatives as merely “means” rather than “elements” on ACCA sentencing?
44:46–53:50
8
What is the Court’s final holding on whether Mathis’s conviction qualifies as an ACCA predicate offense?
53:50–1:01:47