(Slip Opinion) OCTOBER TERM, 2018 1 

Syllabus 

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is 

being done in connection with this case, at the time the opinion is issued. 

The syllabus constitutes no part of the opinion of the Court but has been 

prepared by the Reporter of Decisions for the convenience of the reader. 

See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. 

SUPREME COURT OF THE UNITED STATES 

Syllabus 

QUARLES v. UNITED STATES 

CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR 

THE SIXTH CIRCUIT 

No. 17–778. Argued April 24, 2019—Decided June 10, 2019 

When petitioner Jamar Quarles pled guilty to being a felon in possession of a firearm in violation of 18 U. S. C. §922(g)(1), he also appeared to qualify for enhanced sentencing under the Armed Career 

Criminal Act because he had at least three prior “violent felony” convictions, §924(e). He claimed, however, that a 2002 Michigan conviction for third-degree home invasion did not qualify, even though

§924(e) defines “violent felony” to include “burglary,” and the generic 

statutory term “burglary” means “unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a 

crime,” Taylor v. United States, 495 U. S. 575, 599 (emphasis added). 

Quarles argued that Michigan’s third-degree home invasion statute—

which applies when a person “breaks and enters a dwelling or enters 

a dwelling without permission and, at any time while he or she is entering, present in, or exiting the dwelling, commits a misdemeanor,” 

Mich. Comp. Laws Ann. §750.110a(4)(a) (emphasis added)—swept too 

broadly. Specifically, he claimed, it encompassed situations where 

the defendant forms the intent to commit a crime at any time while 

unlawfully remaining in a dwelling, while generic remaining-in burglary occurs only when the defendant has the intent to commit a 

crime at the exact moment when he or she first unlawfully remains in 

a building or structure. The District Court rejected that argument, 

and the Sixth Circuit affirmed. 

Held: 

1. Generic remaining-in burglary occurs under §924(e) when the 

defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure. In ordinary usage,

“remaining-in” refers to a continuous activity, and this Court has followed that ordinary meaning in analogous legal contexts, see, e.g., 
 

 

 

 

 

2 QUARLES v. UNITED STATES 

Syllabus 

United States v. Cores, 356 U. S. 405, 408. Those contexts thus inform the interpretation of “remaining-in” burglary in §924(e): The 

common understanding of “remaining in” as a continuous event 

means that burglary occurs for purposes of §924(e) if the defendant 

forms the intent to commit a crime at any time during the continuous

event of unlawfully remaining in a building or structure. The intent 

to commit a crime must be contemporaneous with unlawful entry or 

remaining, but the defendant’s intent is contemporaneous with the

unlawful remaining so long as the defendant forms the intent at any 

time while unlawfully remaining. That conclusion is supported by

the body of state law as of 1986, when Congress enacted §924(e). 

Quarles’ narrow interpretation makes little sense in light of Congress’ rationale for specifying burglary as a violent felony. Congress 

“singled out burglary” because of its “inherent potential for harm to 

persons,” Taylor, 495 U. S., at 588, and the possibility of a violent 

confrontation does not depend on the exact moment when the burglar 

forms the intent to commit a crime while unlawfully present in a 

building or structure. Quarles’ interpretation would also thwart the 

stated goals of the Armed Career Criminal Act by presumably eliminating many States’ burglary statutes as predicate offenses under 

§924(e). Pp. 3–9.

2. For the Court’s purposes here, the Michigan home-invasion statute substantially corresponds to or is narrower than generic burglary.

The conclusion that generic remaining-in burglary occurs when the 

defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure resolves this case. 

When deciding whether a state law is broader than generic burglary, 

the state law’s “exact definition or label” does not control. Taylor,

495 U. S., at 599. So long as the state law in question “substantially 

corresponds” to (or is narrower than) generic burglary, the conviction 

qualifies. Ibid. Pp. 9–10. 

 850 F. 3d 836, affirmed. 

KAVANAUGH, J., delivered the opinion for a unanimous Court. THOMAS, J., filed a concurring opinion. 
 

 

 

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Cite as: 587 U. S. ____ (2019) 1 

Opinion of the Court 

NOTICE: This opinion is subject to formal revision before publication in the

preliminary print of the United States Reports. Readers are requested to 

notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order

that corrections may be made before the preliminary print goes to press. 

SUPREME COURT OF THE UNITED STATES 

No. 17–778 

JAMAR ALONZO QUARLES, PETITIONER v. 

UNITED STATES 

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF 

APPEALS FOR THE SIXTH CIRCUIT 

[June 10, 2019] 

JUSTICE KAVANAUGH delivered the opinion of the Court. 

Section 924(e) of Title 18, also known as the Armed 

Career Criminal Act, mandates a minimum 15-year prison 

sentence for a felon who unlawfully possesses a firearm

and has three prior convictions for a “serious drug offense” 

or “violent felony.” Section 924(e) defines “violent felony” 

to include “burglary.” Under this Court’s 1990 decision in 

Taylor v. United States, 495 U. S. 575, the generic statutory term “burglary” means “unlawful or unprivileged entry 

into, or remaining in, a building or structure, with intent 

to commit a crime.” Id., at 599 (emphasis added).

The exceedingly narrow question in this case concerns

remaining-in burglary. The question is whether remainingin burglary (i) occurs only if a person has the intent to

commit a crime at the exact moment when he or she first 

unlawfully remains in a building or structure, or (ii) more 

broadly, occurs when a person forms the intent to commit

a crime at any time while unlawfully remaining in a building or structure. For purposes of §924(e), we conclude that

remaining-in burglary occurs when the defendant forms 

the intent to commit a crime at any time while unlawfully 
 

2 QUARLES v. UNITED STATES 

Opinion of the Court 

remaining in a building or structure. We affirm the judgment of the U. S. Court of Appeals for the Sixth Circuit. 

I 

On August 24, 2013, police officers in Grand Rapids,

Michigan, responded to a 911 call. When the officers 

arrived at the scene, the caller, Chasity Warren, told the

officers that she had just escaped from her boyfriend,

Jamar Quarles. Warren said that Quarles had threatened 

her at gunpoint and also hit her. While the police officers

were speaking with Warren, Quarles drove by. The officers then arrested Quarles and later searched his house. 

Inside they found a semiautomatic pistol. 

Quarles pled guilty to being a felon in possession of a 

firearm in violation of 18 U. S. C. §922(g)(1). Quarles had 

at least three prior convictions that appeared to qualify as 

violent felonies under the Armed Career Criminal Act, 18 

U. S. C. §924(e). Those three convictions were: (1) a 2002

Michigan conviction for third-degree home invasion stemming from an attempt to chase down an ex-girlfriend who 

had sought refuge in a nearby apartment; (2) a 2004 Michigan conviction for assault with a dangerous weapon based 

on an incident where Quarles held a gun to the head of

another ex-girlfriend and threatened to kill her; and (3) a 

2008 Michigan conviction for assault with a dangerous

weapon arising from an altercation with another man and

that same ex-girlfriend in which Quarles shot at the man. 

In the sentencing proceedings for his federal felon-inpossession offense, Quarles argued that his 2002 Michigan 

conviction for third-degree home invasion did not qualify

as a burglary under §924(e). Under this Court’s precedents, the District Court had to decide whether the Michigan statute under which Quarles was convicted in 2002 

was broader than the generic definition of burglary set 

forth in Taylor (in which case the conviction would not

qualify as a prior conviction under §924(e)) or, instead, 
 

 

Cite as: 587 U. S. ____ (2019) 3 

Opinion of the Court 

whether the Michigan statute “substantially correspond[ed]” to or was narrower than the generic definition 

of burglary set forth in Taylor. 495 U. S., at 602. To 

reiterate, Taylor interpreted burglary under §924(e) to 

mean “unlawful or unprivileged entry into, or remaining 

in, a building or structure, with intent to commit a crime.” 

Id., at 599 (emphasis added). 

Under the Michigan law at issue here, a person commits

third-degree home invasion if he or she “breaks and enters 

a dwelling or enters a dwelling without permission and, at 

any time while he or she is entering, present in, or exiting

the dwelling, commits a misdemeanor.” Mich. Comp.

Laws Ann. §750.110a(4)(a) (West 2004) (emphasis added).

Quarles argued to the District Court that the Michigan

third-degree home invasion statute swept too broadly to

qualify as burglary under §924(e) because the Michigan 

statute encompassed situations where the defendant 

forms the intent to commit a crime at any time while 

unlawfully remaining in a dwelling, not at the exact moment when the defendant is first unlawfully present in a 

dwelling. The District Court rejected that argument and 

sentenced Quarles to 17 years in prison. The Sixth Circuit 

affirmed. 850 F. 3d 836, 840 (2017). We granted certiorari in light of a Circuit split on the question of how to assess 

state remaining-in burglary statutes for purposes of 

§924(e). 586 U. S. ___ (2019). 

II 

Section 924(e) lists “burglary” as a qualifying predicate

offense for purposes of the Armed Career Criminal Act. 

But §924(e) does not define “burglary.” The question here

is how to define “burglary” under §924(e). We do not write 

on a clean slate. See Taylor, 495 U. S., at 599. 

At common law, burglary was confined to unlawful 

breaking and entering a dwelling at night with the intent 

to commit a felony. See, e.g., 4 W. Blackstone, Commen-
 

 

4 QUARLES v. UNITED STATES 

Opinion of the Court 

taries on the Laws of England 224 (1769). But by the time

Congress passed and President Reagan signed the current 

version of §924(e) in 1986, state burglary statutes had 

long since departed from the common-law formulation.

See Taylor, 495 U. S., at 593–596. In addition to casting 

off relics like the requirement that there be a breaking, or

that the unlawful entry occur at night, a majority of States

by 1986 prohibited unlawfully “remaining in” a building 

or structure with intent to commit a crime. Those 

remaining-in statutes closed a loophole in some States’ 

laws by extending burglary to cover situations where a person enters a structure lawfully but stays unlawfully—for

example, by remaining in a store after closing time without permission to do so.

In the 1990 Taylor decision, this Court interpreted the

term “burglary” in §924(e) in accord with the more expansive understanding of burglary that had become common 

by 1986: “We believe that Congress meant by ‘burglary’ 

the generic sense in which the term is now used in the 

criminal codes of most States.” 495 U. S., at 598. The 

Court concluded that generic burglary under §924(e) 

means “unlawful or unprivileged entry into, or remaining 

in, a building or structure, with intent to commit a crime.” 

Id., at 599 (emphasis added). A defendant’s prior conviction under a state statute qualifies as a predicate burglary 

under §924(e) if the state statute—regardless of its “exact 

definition or label”—“substantially corresponds” to or is 

narrower than the generic definition of burglary. Id., at 

599, 602. 

In this case, we must determine the scope of generic

remaining-in burglary under Taylor—in particular, the 

timing of the intent requirement. Quarles argues that

remaining-in burglary occurs only when the defendant has 

the intent to commit a crime at the exact moment when he 

or she first unlawfully remains in a building or structure. 

The Government argues for a broader definition of 
 

Cite as: 587 U. S. ____ (2019) 5 

Opinion of the Court 

remaining-in burglary. According to the Government, 

remaining-in burglary occurs when the defendant forms the

intent to commit a crime at any time while unlawfully present

in a building or structure. We agree with the Government.

As noted, Taylor interpreted generic burglary under

§924(e) to include remaining-in burglary. Id., at 599. In 

ordinary usage, “remaining in” refers to a continuous 

activity. See United States v. Cores, 356 U. S. 405, 408 

(1958); see also Webster’s New International Dictionary 

2106 (2d ed. 1949); 8 Oxford English Dictionary 418 

(1933). This Court has followed that ordinary meaning in 

analogous legal contexts. For example, when interpreting

a federal criminal statute punishing any “‘alien crewman

who willfully remains in the United States in excess of the 

number of days allowed,’” the Court stated that “the crucial word ‘remains’ permits no connotation other than

continuing presence.” Cores, 356 U. S., at 408. The law of 

trespass likewise proscribes remaining on the land of

another without permission. In that context, the term 

“remain” refers to “a continuing trespass for the entire 

time during which the actor wrongfully remains.” Restatement (Second) of Torts §158, Comment m, p. 280

(1965).

Those interpretations of “remaining in” in analogous

areas of the law inform our interpretation of “remainingin” burglary in §924(e). In particular, the common understanding of “remaining in” as a continuous event means 

that burglary occurs for purposes of §924(e) if the defendant forms the intent to commit a crime at any time during 

the continuous event of unlawfully remaining in a building 

or structure. To put it in conventional criminal law terms: 

Because the actus reus is a continuous event, the mens rea 

matches the actus reus so long as the burglar forms the 

intent to commit a crime at any time while unlawfully

present in the building or structure. 

Quarles insists, however, that to constitute a burglary 
 

6 QUARLES v. UNITED STATES 

Opinion of the Court 

under §924(e), the intent to commit a crime must be contemporaneous with unlawful entry or remaining. That is 

true. But the defendant’s intent is contemporaneous with

the unlawful remaining so long as the defendant forms the

intent at any time while unlawfully remaining. Put simply, for burglary predicated on unlawful entry, the defendant must have the intent to commit a crime at the time of 

entry. For burglary predicated on unlawful remaining, 

the defendant must have the intent to commit a crime at 

the time of remaining, which is any time during which the 

defendant unlawfully remains.

That conclusion is supported by the States’ laws as of 

1986 when Congress enacted §924(e). As of 1986, a majority of States proscribed remaining-in burglary. At that 

time, there was not much case law addressing the precise 

timing of the intent requirement for remaining-in burglary. That is presumably because in most remaining-in

burglaries, the defendant has the intent to commit a crime 

when he or she first unlawfully remains in a building or 

structure. The timing issue arises only in the rarer cases 

where the defendant forms the intent to commit a crime 

only after unlawfully remaining in the building or structure for a while. In any event, for present purposes, the 

important point is that all of the state appellate courts

that had definitively addressed this issue as of 1986 had 

interpreted remaining-in burglary to occur when the 

defendant forms the intent to commit a crime at any time

while unlawfully present in the building or structure. See 

Gratton v. State, 456 So. 2d 865, 872 (Ala. Crim. App. 

1984); State v. Embree, 130 Ariz. 64, 66, 633 P. 2d 1057, 

1059 (App. 1981); Keith v. State, 138 Ga. App. 239, 225 S. 

E. 2d 719, 720 (1976); State v. Mogenson, 10 Kan. App. 2d 

470, 472–476, 701 P. 2d 1339, 1343–1345 (1985); State v. 

Papineau, 53 Ore. App. 33, 38, 630 P. 2d 904, 906–907 
Cite as: 587 U. S. ____ (2019) 7 

Opinion of the Court 

(1981).1 

Especially in light of the body of state law as of 1986, it

is not likely that Congress intended generic burglary

under §924(e) to include (i) a burglar who intends to commit a crime at the exact moment when he or she first 

unlawfully remains in a building or structure, but to 

exclude (ii) a burglar who forms the intent to commit a 

crime at any time while unlawfully remaining in a building or structure.

Indeed, excluding that latter category of burglaries from 

generic burglary under §924(e) would make little sense in

light of Congress’ rationale for specifying burglary as a 

violent felony. As the Court recognized in Taylor, Congress “singled out burglary” because of its “inherent potential for harm to persons.” 495 U. S., at 588. Burglary is 

dangerous because it “creates the possibility of a violent 

—————— 

1The consensus position has not changed. Today, of the States that 

have addressed the question, at least 18 have adopted the “at any time” 

interpretation of remaining-in burglary, and only 3 appear to have 

adopted the narrower interpretation. 

Of those 18 States, some have adopted the broader “at any time” 

interpretation by statute. See Colo. Rev. Stat. §18–4–201(3) (2018);

Del. Code Ann., Tit. 11, §829(e) (2015); Haw. Rev. Stat. Ann. §708– 

812.5 (2014); Mich. Comp. Laws Ann. §750.110a(4)(a) (West 2004); 

Minn. Stat. §§609.581(4), 609.582(3) (2016); Mont. Code Ann. §45–6– 

204(1) (2017); Tenn. Code Ann. §39–14–402(a)(3) (2018); Tex. Penal 

Code Ann. §30.02(a)(3) (West 2019). And in addition to the five pre1986 state-court decisions identified in the text above, at least five post1986 state-court decisions have adopted the “at any time” interpretation of “remaining in.” See Braddy v. State, 111 So. 3d 810, 844 (Fla. 

2012) (per curiam); State v. Walker, 600 N. W. 2d 606, 609 (Iowa 1999); 

State v. DeNoyer, 541 N. W. 2d 725, 732 (S. D. 1995); State v. Rudolph, 

970 P. 2d 1221, 1228–1229 (Utah 1998); State v. Allen, 127 Wash. App. 

125, 135, 110 P. 3d 849, 853–855 (2005).

By contrast, three state courts appear to have adopted the narrower 

interpretation. Shetters v. State, 751 P. 2d 31, 36, n. 2 (Alaska App. 

1988); People v. Gaines, 74 N. Y. 2d 358, 361–363, 546 N. E. 2d 913, 

915–916 (1989); In re J. N. S., 258 Ore. App. 310, 318–319, 308 P. 3d 

1112, 1117–1118 (2013). 
 

 

8 QUARLES v. UNITED STATES 

Opinion of the Court 

confrontation between the offender and an occupant,

caretaker, or some other person who comes to investigate.” 

Ibid.; see also United States v. Stitt, 586 U. S. ___, ___ 

(2018) (slip op., at 6). 

With respect to remaining-in burglary, the possibility of 

a violent confrontation does not depend on the exact moment when the burglar forms the intent to commit a crime 

while unlawfully present in a building or structure. Once 

an intruder is both unlawfully present inside a building or 

structure and has the requisite intent to commit a crime, 

all of the reasons that led Congress to include burglary as

a §924(e) predicate fully apply. The dangers of remainingin burglary are not tied to the esoteric question of precisely 

when the defendant forms the intent to commit a crime. 

That point underscores that Congress, when enacting 

§924(e) in 1986, would not have understood the meaning

of burglary to hinge on exactly when the defendant forms 

the intent to commit a crime while unlawfully present in a 

building or structure. 

Moreover, to interpret remaining-in burglary narrowly,

as Quarles advocates, would thwart the stated goals of the 

Armed Career Criminal Act. After all, most burglaries 

involve unlawful entry, not unlawful remaining in. Yet if 

we were to narrowly interpret the remaining-in category

of generic burglary so as to require that the defendant 

have the intent to commit a crime at the exact moment he 

or she first unlawfully remains, then many States’ burglary statutes would be broader than generic burglary. As a 

result, under our precedents, many States’ burglary statutes would presumably be eliminated as predicate offenses 

under §924(e). That result not only would defy common

sense, but also would defeat Congress’ stated objective of 

imposing enhanced punishment on armed career criminals

who have three prior convictions for burglary or other

violent felonies. We should not lightly conclude that Congress enacted a self-defeating statute. See, e.g., Stokeling 
 

Cite as: 587 U. S. ____ (2019) 9 

Opinion of the Court 

v. United States, 586 U. S. ___, ___ (2019) (slip op., at 8); 

Taylor, 495 U. S., at 594. 

To sum up: The Armed Career Criminal Act does not 

define the term “burglary.” In Taylor, the Court explained

that “Congress did not wish to specify an exact formulation that an offense must meet in order to count as ‘burglary’ for enhancement purposes.” Id., at 599. And the 

Court recognized that the definitions of burglary “vary” 

among the States. Id., at 598. The Taylor Court therefore 

interpreted the generic term “burglary” in §924(e) in light

of: the ordinary understanding of burglary as of 1986; the 

States’ laws at that time; Congress’ recognition of the 

dangers of burglary; and Congress’ stated objective of 

imposing increased punishment on armed career criminals

who had committed prior burglaries. Looking at those 

sources, the Taylor Court interpreted generic burglary

under §924(e) to encompass remaining-in burglary. Looking at those same sources, we interpret remaining-in

burglary under §924(e) to occur when the defendant forms 

the intent to commit a crime at any time while unlawfully 

present in a building or structure. 

III 

In light of our conclusion that generic remaining-in

burglary occurs when the defendant forms the intent to 

commit a crime at any time while unlawfully remaining in 

a building or structure, Quarles’ case is easily resolved. 

The question in Quarles’ case is whether the Michigan

home-invasion statute under which he was convicted in 

2002 is broader than generic burglary or, instead, “substantially corresponds” to or is narrower than generic

burglary. Id., at 602. Regarding that inquiry, the Taylor

Court cautioned courts against seizing on modest statelaw deviations from the generic definition of burglary. A 

state law’s “exact definition or label” does not control. Id., 

at 599. As the Court stated in Taylor, so long as the state 
 

10 QUARLES v. UNITED STATES 

Opinion of the Court 

law in question “substantially corresponds” to (or is narrower than) generic burglary, the conviction qualifies 

under §924(e). Id., at 602. 

As stated above, generic remaining-in burglary occurs

under §924(e) when the defendant forms the intent to

commit a crime at any time while unlawfully remaining in 

a building or structure. For the Court’s purposes here, the

Michigan statute substantially corresponds to or is narrower than generic burglary.2 

* * * 

We affirm the judgment of the U. S. Court of Appeals for 

the Sixth Circuit. 

It is so ordered. 

—————— 

2 In his brief, Quarles alternatively suggests that Michigan’s homeinvasion statute actually does not require that the defendant have any

intent to commit a crime at any time while unlawfully present in a 

dwelling. Brief for Petitioner 9. Quarles offers no support for his 

suggestion that there is no mens rea requirement. In any event, 

Quarles did not preserve that argument, and we do not address it. 
 

 

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Cite as: 587 U. S. ____ (2019) 1 

THOMAS, J., concurring 

SUPREME COURT OF THE UNITED STATES 

No. 17–778 

JAMAR ALONZO QUARLES, PETITIONER v. 

UNITED STATES 

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF 

APPEALS FOR THE SIXTH CIRCUIT 

[June 10, 2019] 

JUSTICE THOMAS, concurring. 

I join the opinion of the Court because it correctly applies our precedent requiring a “categorical approach” to

the enumerated-offenses clause of the Armed Career 

Criminal Act (ACCA). I write separately to question this 

approach altogether.

This case demonstrates the absurdity of applying the

categorical approach to the enumerated-offenses clause. 

The categorical approach relies on a comparison of the 

crime of conviction and a judicially created ideal of burglary. But this ideal is starkly different from the reality

of petitioner’s actual crime: Petitioner attempted to climb

through an apartment window to attack his ex-girlfriend. 

More importantly, there are strong reasons to suspect

that the categorical approach described in Taylor v. United 

States, 495 U. S. 575 (1990), is not compelled by

ACCA’s text but was rather a misguided attempt to avoid 

Sixth Amendment problems. See Sessions v. Dimaya, 584 

U. S. ___, ___–___ (2018) (THOMAS, J., dissenting) (slip op., 

at 21–23). Under our precedent, any state burglary statute with a broader definition than the one adopted in 

Taylor is categorically excluded simply because other

conduct might be swept in at the margins. It is far from 

obvious that this is the best reading of the statute. A jury 

could readily determine whether a particular conviction 
 

 

 

2 QUARLES v. UNITED STATES 

THOMAS, J., concurring 

satisfied the federal definition of burglary or instead fell 

outside that definition. See Ovalles v. United States, 905 

F. 3d 1231, 1258–1260 (CA11 2018) (W. Pryor, J., concurring). Moreover, allowing a jury to do so would end the

unconstitutional judicial factfinding that occurs when 

applying the categorical approach. See, e.g., Dimaya, 

supra, at ___–___ (opinion of THOMAS, J.) (slip op., at 22– 

23); Mathis v. United States, 579 U. S. ___, ___ (2016) 

(THOMAS, J., concurring) (slip op., at 2); Descamps v. United 

States, 570 U. S. 254, 280 (2013) (THOMAS, J., concurring 

in judgment); James v. United States, 550 U. S. 192, 231– 

232 (2007) (THOMAS, J., dissenting); Shepard v. United 

States, 544 U. S. 13, 26–28 (2005) (THOMAS, J., concurring 

in part and concurring in judgment). 

Of course, addressing this issue would not help petitioner: 

He has not preserved a Sixth Amendment challenge.

Moreover, any reasonable jury reviewing the record here

would have concluded that petitioner was convicted of 

burglary, so any error was harmless. 

* * * 

Because the categorical approach employed today is

difficult to apply and can yield dramatically different 

sentences depending on where a burglary occurred, the 

Court should consider whether its approach is actually

required in the first place for ACCA’s enumerated-offenses 

clause. With these observations, I join the opinion of the 

Court.