United States v. Victor Stitt

There is an easy way to think about this case. And there is a more complicated way. Either way, Stitt’s conviction under Tennessee law for aggravated burglary counts as a “burglary” under the Armed Career Criminal Act.

The easy way. The Armed Career Criminal Act establishes a mandatory minimum sentence for firearm offenders who have three previous convictions for “violent felonies] or [] serious drug offense[s].” 18 U.S.C. § 924(e)(1). The Act lists “burglary” as a qualifying violent felony. Id. § 924(e)(2)(B)(ii). The relevant portion of Tennessee’s aggravated burglary statute applies to…