U.S. v. Glispie

Ct. of Appeals drafted certified question to Illinois Supreme Ct. to determine whether defendant’s Illinois conviction for residential burglary by entry qualified him for enhanced sentencing treatment under Armed Career Criminal Act (ACCA). Illinois Supreme Ct. found that limited-authority doctrine applied to residential burglary by entry offense, which, according to Ct. of Appeals, made Illinois residential burglary by entry offense broader than federal generic burglary offense as defined in Taylor, 495 U.S. 575, and thus precluded use of said conviction to enhance defendant’s sentence under ACCA. As such, defendant was entitled to new sentencing hearing without ACCA enhancement.