Taylor v. United States

The Court rejected a state-law definition because it would make a federal sentencing enhancement turn on varying state labels rather than on the defendant's conduct and the elements of the offense. Identical conduct could qualify in a State with a broad offense called burglary but not in a State that used a different label, such as breaking and entering. Congress gave no clear indication that it intended this arbitrary, state-dependent result.

The Court also rejected the traditional common-law definition, which required breaking and entering the dwelling of another at night with intent to commit a felony. By 1986, most States had abandoned those technical limits, and the common-law formulation did not fit Congress's practical concern with repeat offenders whose burglaries create a serious possibility of violent confrontation.

Taylor's proposed limitation to especially dangerous burglaries likewise failed. Section 924(e)(2)(B)(ii) separately lists burglary alongside arson, extortion, and crimes involving explosives, before covering offenses that otherwise present a serious potential risk of physical injury. If Congress had intended to reach only burglaries with additional dangerous elements, there would have been little reason to list burglary separately.

The statutory history supported a categorical and modern understanding. The 1984 predecessor statute expressly used a broad definition substantially matching generic burglary, and nothing in the 1986 amendment showed that Congress meant to replace it with either state-specific labels or the obsolete common-law rule. The deletion of the earlier definition at most showed that Congress did not intend to prescribe an exact verbal formula.

Accordingly, a prior offense counts as burglary regardless of the title given it under state law if its elements require unlawful or unprivileged entry into, or remaining in, a building or structure with intent to commit a crime. The rule of lenity did not justify a narrower reading because that reading would conflict with the term's generally accepted contemporary meaning and the statute's evident design.

The statute speaks in terms of prior convictions, not prior conduct. It defines a violent felony in part as a crime that "has as an element" the use or threatened use of force. Read in that context, the phrase "is burglary" likewise ordinarily directs the sentencing court to the legal elements of the offense rather than to a factual reconstruction of the earlier crime.

A broad factual inquiry would create substantial practical and fairness problems. Sentencing courts might have to review old trial transcripts, hear witness testimony, determine which theory supported a jury verdict, or reconstruct the facts of a guilty plea. That process would be especially unreliable where records were sparse or a plea bargain had reduced the charge.

The categorical rule permits a narrow exception when reliable conviction records establish that the prior conviction necessarily rested on generic burglary. For example, where a statute covers burglaries of both buildings and automobiles, an indictment and jury instructions showing that the charge concerned a building and that the jury had to find entry into a building may establish a qualifying conviction.

The record did not reveal which of Missouri's several second-degree burglary statutes formed the basis of Taylor's convictions. Some Missouri provisions matched generic burglary, while at least one reached places such as boats, railroad cars, booths, and tents. The Court therefore vacated the judgment and remanded for proceedings consistent with its rule.