US v. Carr: Carr pleaded guilty to being a felon in possession of a firearm. He had 13 prior felony convictions in North Carolina for breaking or entering, leading the district court to determine he qualified as an Armed Career Criminal. Carr agreed that he had the 13 convictions, but argued that they did not occur "on occasions different from one another." Specifically, the 13 convictions stemmed from 13 indictments for breaking into 13 different storage units at a self-store complex. The district court rejected that argument and sentenced Carr to 262 months in prison.
On appeal, the Fourth Circuit rejected Carr's argument as well and affirmed his sentence. After surveying prior cases addressing the issue of whether ACCA predicates were part of "separate and distinct criminal episodes," the court concluded that Carr's prior offenses, although all taking place in one general location, were separate episodes. Noting the disjunctive nature of the charges (breaking or entering), the court concluded that each offense was complete when each unit was opened, regardless of whether Carr went back and forth between the units once they were open.