Erlinger v. United States (2024)

1) Link to the Actual Opinion
Read the Supreme Court opinion (PDF)

2) Summary of the Opinion
Erlinger was convicted under the Armed Career Criminal Act (ACCA), which imposes enhanced sentences for defendants with three prior convictions committed on “occasions different from one another.” The sentencing judge, not a jury, determined that Erlinger’s prior convictions were from separate occasions. The Supreme Court held this violated the Sixth Amendment: such facts must be found by a jury, unanimously, and proven beyond a reasonable doubt.

3) Why It Mattered
It reinforced the jury trial right in sentencing, continuing a trend from Apprendi v. New Jersey (2000) and its progeny. The decision limits judicial fact-finding that increases mandatory minimums.

4) What It Provided or Took Away

• Provided: Stronger jury protections in sentencing; juries must decide key facts that trigger enhanced penalties.
• Took Away: Judges’ ability to unilaterally determine the “different occasions” requirement under ACCA.

5) Overreach or Proper Role?
The Court properly enforced the Sixth Amendment. Critics worry it complicates sentencing; supporters say it strengthens core constitutional protections.

6) Plain-English Impact Today
If the government wants to give you a longer sentence based on your criminal history, a jury—not just the judge—has to decide the key facts that trigger the harsher penalty.

• Sixth Amendment
• Jury Trial
• Sentencing
• Armed Career Criminal Act