Background
Myles Antonio Jones pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g) and 924(e). The U.S. District Court for the Eastern District of Arkansas sentenced him to 180 months in prison under the Armed Career Criminal Act.
Jones appealed, arguing that he should not have been sentenced as an armed career criminal because two of his prior convictions did not qualify as separate offenses. The ACCA imposes a minimum 15-year sentence when a person who violates § 922(g) has three prior convictions for violent felonies committed on occasions different from one another.
The Court’s Holding
The Eighth Circuit affirmed the 180-month sentence. Reviewing the issue de novo, the court concluded that the district court did not err because Jones admitted during his change-of-plea hearing that he had been convicted of three residential burglaries committed on different occasions.
The court explained that whether prior offenses occurred on different occasions is a fact that ordinarily must be found unanimously by a jury beyond a reasonable doubt. Under the Supreme Court’s decision in Erlinger v. United States, however, that fact may instead support an ACCA enhancement when the defendant freely admits it in a guilty plea. Jones’s admission satisfied that requirement.
Key Takeaways
- Three residential-burglary convictions committed on different occasions supported Jones’s ACCA sentence.
- A defendant’s free admission during a guilty plea can establish that prior offenses occurred on different occasions.
- The Eighth Circuit affirmed Jones’s mandatory minimum sentence of 180 months.
Why It Matters
The unpublished decision illustrates how a defendant’s admissions during a plea hearing can establish the ACCA’s different-occasions requirement without a separate jury finding. Defense counsel should carefully assess factual admissions concerning prior offenses because those admissions may determine whether the 15-year mandatory minimum applies.