William Dale Wooden burglarized ten units in a single storage facility one night. He later pleaded guilty to ten counts of burglary—one for each storage unit he had entered. The district court concluded these convictions subjected him to the Armed Career Criminal Act which mandates a 15-year minimum sentence for unlawful gun possession when the offender has three or more prior convictions for violent felonies “committed on occasions different from one another.” The question was whether these prior convictions counted as different occasions because the burglary of each unit happened at a distinct point in time, or whether they occurred simultaneously. The Supreme Court held they were simultaneous. In other words, convictions stemming from a single criminal episode count just once under the ACCA.

Wooden v. United States