United States v. Erlinger, 77 F.4th 617 (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 the Armed Career Criminal Act, 18 U.S.C. § 924(e)(1).
Erlinger v. United States, 602 U.S. ___ (2024) was a United States Supreme Court case relating to the right to a jury trial in criminal cases under the Fifth and Sixth Amendments. The case was argued on January 16, 2024, and decided on June 21.
Background
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 the ACCA enhancement.[2] Erlinger objected, arguing that the burglary question should have been found by a jury.[2] The Supreme Court held in Apprendi 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."