Whitfield Leland, III v. United States

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)?