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Whitfield Leland, III v. United States
IFP petition · United States Court of Appeals for the Eleventh Circuit, No. 25-12739 · judgment April 8, 2026
Question presented
To determine whether a prior state conviction qualifies as a predicate under the Armed Career Criminal Act (ACCA), federal courts apply the categorical approach. Under that approach, federal courts identify the elements of the state offense. To do so, they must consult state court decisions interpreting the state statute. This case involves the following, recurring scenario: after the defendant’s prior state conviction, a state court issues a decision changing the scope of the offense elements in a manner that would affect whether the offense qualifies under the Armed Career Criminal Act. The question presented is: To determine the elements of a prior state conviction for purposes of applying ACCA’s categorical approach, should federal courts consult the most recent, authoritative state court decisions (as the Eleventh Circuit holds), or the state court decisions in place at the time of the defendant’s prior conviction (as at least two other circuits hold)?
Counsel of record
For petitioner
Megan Jean Saillant
Office of the Fed. Pub. Def. for the NDFL
For respondent
D. John Sauer
Solicitor General
Case
Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
Distributed for 1 conference
Proceedings
- Sep 14 2026Motion to extend the time to file a response is granted and the time is extended to and including October 19, 2026.
- Sep 11 2026Motion to extend the time to file a response from September 18, 2026 to October 19, 2026, submitted to The Clerk.
- Aug 19 2026Response Requested. (Due September 18, 2026)
- Aug 13 2026DISTRIBUTED for Conference of 9/28/2026.
- Aug 05 2026Waiver of right of respondent United States to respond filed.
- Jul 07 2026Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due August 19, 2026)