Petition for Writ of Certiorari — Richard Schorovsky, Petitioner v. United States

No. ___________

________________________________________________________

IN THE SUPREME COURT OF THE UNITED STATES

________________________________________________________

October Term, 2023

________________________________________________________

RICHARD SCHOROVSKY,

SCHOROVSKY

Petitioner

v.

UNITED STATES OF AMERICA,

AMERICA

Respondent

________________________________________________________

MOTION FOR LEAVE TO FILE IN FORMA PAUPERIS

________________________________________________________

The Petitioner, Richard Schorovsky, requests leave, pursuant to

Rule 39.1 of the Supreme Court Rules, to file the attached Petition for a

Writ of Certiorari without prepayment of costs and to proceed in forma

pauperis.

Petitioner has previously sought and been granted leave to proceed

in forma pauperis in the following court: The United States District Court

for the Western District of Texas.

Undersigned counsel was admitted to practice before the U.S.

Supreme Court June 23rd, 2014. Additionally, undersigned counsel has

1

been appointed under the Criminal Justice Act of 1964, 18 USC § 3006A.

Respectfully submitted,

/s/ John A. Kuchera

JOHN A. KUCHERA

210 N. 6th St.

Waco, Texas 76701

(254) 754-3075

(254) 756-2193 (facsimile)

johnkuchera@210law.com

SBN 00792137

Attorney for Petitioner

2

No. ___________

________________________________________________________

IN THE SUPREME COURT OF THE UNITED STATES

________________________________________________________

October Term, 2023

________________________________________________________

RICHARD SCHOROVSKY,

SCHOROVSKY

Petitioner

v.

UNITED STATES OF AMERICA,

AMERICA

Respondent

________________________________________________________

Petition for Writ of Certiorari

to the United States Court of Appeals

for the Fifth Circuit

________________________________________________________

________________________________________________________

PETITION FOR WRIT OF CERTIORARI

________________________________________________________

JOHN A. KUCHERA

210 N. 6th St.

Waco, Texas 76701

(254) 754-3075

(254) 756-2193 (facsimile)

johnkuchera@210law.com

SBN 00792137

Attorney for Petitioner

i

Questions

Questions Presented

1. In light of Erlinger v. United States, No. 23-370, 602 U.S. ___ (June

21, 2024), was Petitioner Schorovsky properly sentenced as an armed

career criminal based on a finding by the district court (not a jury) that

Petitioner’s two prior robbery convictions were committed on separate

occasions?

2. In light of Erlinger v. United States, No. 23-370, 602 U.S. ___ (June

21, 2024), was it proper for the sentencing court to rely on Shepard

approved documents to determine whether Petitioner’s prior robbery

convictions occurred on separate occasions?

3. In light of United States v. Stitt, 139 S.Ct. 399 (2018), can the Texas

burglary statute – which the Fifth Circuit has held to be indivisible –

properly be the basis for an enhanced sentence under the Armed Career

Criminal Act, given that a person can be convicted under the statute for

doing nothing more than entering a storage building with the intent to

commit theft?

ii

Table of Contents

Page

Questions Presented

ii

Table of Contents

iii-iv

Table of Authorities

v-vi

Citation to Opinion Below

1

Federal Statutes

2-3

Texas Statutes

3

Statement of the Case

4-6

First Reason for Granting the Writ: The Fifth Circuit’s holding 7

that a judge, by himself, can find the fact that prior offenses

were committed on separate occasions is inconsistent with the

Supreme Court’s recent opinion in Erlinger v. United States,

No. 23-370, 602 U.S. ___ (June 21, 2024).

Second Reason for Granting the Writ: The Fifth Circuit’s

8-9

holding that a judge can consult Shepard-approved documents

to determine whether prior offenses were committed on

separate occasions is inconsistent with the Supreme Court’s

recent opinion in Erlinger v. United States, No. 23-370, 602

U.S. ___ (June 21, 2024).

Third Reason for Granting the Writ: Because the Texas

9-14

burglary statute allows for conviction based upon burglarizing

structures used only for storage, burglary in Texas cannot

be generic burglary in light of the Supreme Court’s decision

in United States v. Stitt, 586 U.S. __, 139 S.Ct. 399 (2018).

iii

Conclusion

14

Certificate of Service

15

Appendix A: Opinion of Fifth Circuit Court of Appeals

Appendix B: Denial of Petition for Rehearing En Banc

iv

Table of Authorities

Page(s)

Cases

Allen v. State,

719 S.W.2d 258 (Tex. App.—Waco 1986, no pet.) .............................. 14

Batiste v. State,

1993 Tex. App. LEXIS 3020 (Tex. App.—Houston [1st

Dist.] 1993, no pet.) ............................................................................. 13

Bryan v. State,

No. 04-22-00757-CR, 2023 Tex. App. LEXIS 8609 (Tex.

App.—San Antonio Nov. 15, 2023, no pet. h.)

(unpublished) ...................................................................................... 14

Davidson v. State,

Nos. 03-20-00146-CR, 03-20-00147-CR, 2021 Tex. App.

LEXIS 5033 (Tex. App.—Austin June 24, 2021, no pet.)

(unpublished) ...................................................................................... 14

Deanda v. State,

No. 13-20-00022-CR, 2021 Tex. App. LEXIS 1833 (Tex.

App.—Corpus Christi Mar. 11, 2021, no pet.)

(unpublished) ...................................................................................... 15

Ellett v. State,

607 S.W.2d 545 (Tex. Crim. App. 1980) ............................................. 13

Erlinger v. United States,

No. 23-370, 602 U.S. ___ (June 21, 2024) ................................... 8, 9, 10

Frizzell v. State,

1987 Tex. App. LEXIS 8318 (Tex. App.—Houston [14th

Dist.] 1987, no pet.) (unpublished) ..................................................... 13

v

Gomez v. State,

No. 11-21-00236-CR, 2023 Tex. App. LEXIS 3582 (Tex.

App.—Eastland May 25, 2023,

In re J.T.,

824 S.W.2d 671 (Tex. App.—Fort Worth 1992, no pet.)..................... 13

Kemp v. State,

2020 Tex. App. LEXIS 2506 (Tex. App.—Fort Worth Mar.

26, 2020, no pet.) (unpublished) ......................................................... 14

Lopez v. State,

660 S.W.2d 592 (Tex. App.—Corpus Christi 1983, pet.

ref’d) .................................................................................................... 14

Mathis v. United States,

136 S.Ct. 2243 (2016) .................................................................... 11, 12

Shepard v. United States,

544 U.S. 13 (2005) ............................................................................. 6, 9

Taylor v. United States,

495 U.S. 575 (1990) ....................................................................... 11, 12

United States v. Schorovsky,

95 F. 4th 945 (5th Cir. 2024) ............................................................ 6, 7

United States v. Stitt,

139 S.Ct. 399 (2018) .................................................................... passim

Warren v. State,

2020 Tex. App. LEXIS 2473 (Tex. App.—Tyler 2020, pet.

ref’d) (unpublished) ............................................................................. 12

Wilson v. State,

1998 Tex. App. LEXIS 6044 (Tex. App.—Dallas 1998)

(unpublished) ...................................................................................... 13

vi

Ysassi v. State,

1998 Tex. App. LEXIS 3459 (Tex. App.—Dallas 1998, no

pet.) (unpublished) ............................................................................. 13

Statutes

18 U.S.C. § 922(g)(1).................................................................................. 3

18 U.S.C. § 924(e)(1) .................................................................................. 3

18 U.S.C. § 924(e)(2)(B) ............................................................................. 3

18 U.S.C. § 924(e)(2)(B)(ii) ...................................................................... 10

Tex. Penal Code Ann. § 30.01 ................................................................... 4

Tex. Penal Code Ann. § 30.02(a) ........................................................... 4, 7

vii

PETITION FOR WRIT OF CERTIORARI

Petitioner Richard Schorovsky respectfully petitions for a writ of

certiorari to review the judgment of the United States Court of Appeals

for the Fifth Circuit.

Citation to Opinion Below

The opinion of the United States Court of Appeals for the Fifth

Circuit affirming Schorovsky’s sentence is styled: United States v.

Schorovsky, 95 F.3d 945, (5th Cir. 2024).

Jurisdiction

The opinion of the United States Court of Appeals for the Fifth

Circuit affirming Schorovsky’s sentence was announced on March 15,

2024 and is attached hereto as Appendix A. Schorovsky’s petition for

rehearing en banc was denied April 5, 2024. The order denying rehearing

is attached hereto as Appendix B. Pursuant to Supreme Court Rule 13.3,

this Petition has been filed within 90 days of the date the petition for

rehearing was denied. This Court’s jurisdiction is invoked pursuant to 28

U.S.C. § 1254(1).

1

Federal Statutes:

18 U.S.C. § 922(g)

922(g)(1):

(1):

It shall be unlawful for any person . . . who has been convicted

in any court of, a crime punishable by imprisonment for a

term exceeding one year . . . to ship or transport in interstate

or foreign commerce, or possess in or affecting commerce, any

firearm or ammunition; or to receive any firearm or

ammunition which has been shipped or transported in

interstate or foreign commerce.

18 U.S.C. § 924(

924(e)(1):

(1):

In the case of a person who violates section 922(g) of this title

and has three previous convictions by any court referred to in

section 922(g)(1) of this title for a violent felony or a serious

drug offense, or both, committed on occasions different from

one another, such person shall be fined under this title and

imprisoned not less than fifteen years, and notwithstanding

any other provision of law, the court shall not suspend the

sentence of, or grant a probationary sentence to, such person

with respect to the conviction under section 922(g).

18 U.S.C. § 924(e)(2)(B):

924(e)(2)(B):

[T]he term violent felony means any crime punishable by

imprisonment for a term exceeding one year, or any act of

juvenile delinquency involving the use or carrying of a

firearm, knife, or destructive device that would be punishable

by imprisonment for such term if committed by an adult, that

– has an element the use, attempted use, or threatened use of

physical force against the person of another; or is burglary,

arson, or extortion, involves use of explosives, or otherwise

2

involves conduct that presents a serious potential risk of

physical injury to another[.]

Texas Statutes

Statutes

Tex. Penal Code Ann. § 30.02(a):

(a) A person commits an offense if, without the effective

consent of the owner, the person:

(1) enters a habitation, or a building (or any portion of a

building) not then open to the public, with intent to commit

a felony, theft, or an assault; or

(2) remains concealed, with intent to commit a felony, theft,

or an assault, in a building or habitation; or

(3) enters a building or habitation and commits or attempts

to commit a felony, theft, or an assault.

Tex. Penal Code Ann. § 30.01:

(1) “Habitation” means a structure or vehicle that is adapted

for the overnight accommodation of persons, and includes:

(A) each separately secured or occupied portion of the

structure or vehicle; and

(B) each structure appurtenant to or connected with the

structure or vehicle.

(2) “Building” means any enclosed structure intended for use

or occupation as a habitation or for some purpose of trade,

manufacture, ornament, or use.

3

Statement of the Case

Schorovsky has two prior Texas robbery convictions and a prior

Texas burglary conviction. These three convictions were the predicates

for applying the Armed Career Criminal Act (ACCA) in determining his

sentence.

As to the robbery convictions, Schorovsky objected in writing to the

robberies being characterized as ACCA predicates:

Mr. Schorovsky objects to the Chapter Four Enhancement

and being labeled an armed career criminal. Mr. Schorovsky’s

2012 offenses should be considered part of the same criminal

episode as they occurred in short succession, resulting in the

same arrest and conviction date.

The district court, in overruling Schorovsky’s objection, specifically relied

upon the charging instruments and judgments in determining that the

offenses had been committed on occasions separate from one another.

Schorovsky argued on appeal (1) that it was improper for the

district court to find a fact (that the robberies had been committed on

separate occasions) that resulted in an increase in Schrovsky’s statutory

range of punishment from zero to fifteen years, to fifteen years to life,

and (2) that indictments and judgments from the prior convictions were

not reliable in establishing whether the offenses were committed on

4

separate occasions. More specifically, under Texas law the date alleged

in an indictment establishes only that the offense conduct occurred prior

to the presentment of the indictment, and that the offense conduct

occurred within the statutory limitations period. And statements of nonelemental facts – like dates – set forth in judgments are prone to error

“precisely because their proof is unnecessary.”

The Fifth Circuit, relying upon circuit precedent, rejected both

arguments:

Shepard-approved1 documents are conclusive as to whether

the predicate ACCA offense occurred on separate occasions.

United States v. Schorovsky, 95 F. 4th 945, 947 (5th Cir. 2024).

Consistent with Apprendi, we have held that because

[Section] 924(e)(1) does not create a separate offense but is

merely a sentence enhancement provision, neither the statute

nor the Constitution requires a jury finding on the existence

of the three previous felony convictions required for the

enhancement. (Cleaned up.)

Id. at 948.

As to the burglary predicate, Schorovsky noted that (1) Fifth Circuit

precedent has determined the Texas burglary statute to be indivisible,

and (2) in United States v. Stitt, 139 S.Ct. 399 (2018), the Supreme Court

1 Shepard v. United States, 544 U.S. 13 (2005).

5

held that generic “burglary” for purposes of the ACCA must include

burglarizing “a structure or vehicle that has been adapted or is

customarily used for overnight accommodation.”

Schorovsky argued that because Texas case law is replete with

burglary convictions where the structure at issue was used only for

storage, Texas burglary – in light of Stitt – does not necessarily constitute

generic burglary. The Fifth Circuit’s response was again to rely on

binding circuit precedent:

Binding circuit precedent forecloses this argument. Burglary

is an enumerated "violent felony" under the ACCA. We

previously held en banc that Penal Code § 30.02(a) fits within

the generic definition of burglary and thus qualifies as an

ACCA violent felony. Since that decision in Herrold II, we

have reiterated that § 30.02(a) constitutes generic burglary in

its entirety, and thus any § 30.02(a) conviction qualifies as a

predicate under the ACCA. (Cleaned up.)

Schorovsky, 95 F.4th at 949.

6

First Reason for Granting the Writ: The Fifth Circuit’s holding that

a judge, by himself, can find the fact that prior offenses were committed

on separate occasions is inconsistent with the Supreme Court’s recent

opinion in Erlinger v. United States, No. 23-370, 602 U.S. ___ (June 21,

2024).

In Erlinger, wherein the petitioner was sentenced as an armed

career criminal based on prior burglary convictions and argued that it

was improper for a district judge to find the fact that the burglaries had

taken place on separate occasions, this Court held that a judge cannot so

find:

Judges may not assume the jury’s factfinding function for

themselves, let alone purport to perform it using a mere

preponderance-of-the-evidence standard.

Erlinger, 602 U.S. at ____, (slip op., at 11).

Presented with evidence about the times, locations, purpose,

and character of [the burglaries], a jury might have concluded

that some or all occurred on different occasions. Or it might

not have done so. All we can say for certain is that the

sentencing court erred in taking that decision from a jury of

Mr. Erlinger’s peers.

Erlinger, 602 U.S. at ____, (slip op., at 12).

7

Second Reason for Granting the Writ: The Fifth Circuit’s holding

that a judge can consult Shepard-approved documents to determine

whether prior offenses were committed on separate occasions is

inconsistent with the Supreme Court’s recent opinion in Erlinger v.

United States, No. 23-370, 602 U.S. ___ (June 21, 2024).

Erlinger holds that a sentencing judge can consult Shepard

documents to determine if a defendant has prior convictions – but not

determine therefrom whether those prior convictions resulted from acts

committed on separate occasions:

To

conduct

the

narrow

inquiry Almendarez-Torres

authorizes, a court may need to know the jurisdiction in which

the defendant’s crime occurred and its date in order to

ascertain what legal elements the government had to prove to

secure a conviction in that place at that time. And to answer

those questions, a sentencing court may sometimes consult a

restricted set of materials, often called Shepard documents,

that include judicial records, plea agreements, and colloquies

between a judge and the defendant.

...

None of that, however, means that a court may

use Shepard documents or any other materials for any other

purpose. To ensure compliance with the Fifth and Sixth

Amendments, a sentencing judge may use the information he

gleans from Shepard documents for the limited function of

determining the fact of a prior conviction and the thenexisting elements of that offense. . . . No more is allowed. . . .

In particular, a judge may not use information

in Shepard documents to decide what the defendant . . .

actually did, or the means or manner in which he committed

8

his offense in order to increase the punishment to which he

might be exposed. (Cleaned up.)

Erlinger, 602 U.S. at ____, (slip op., at 15-16).

Third Reason for Granting the Writ: Because the Texas burglary

statute allows for conviction based upon burglarizing structures used

only for storage, burglary in Texas cannot be generic burglary in light of

the Supreme Court’s decision in United States v. Stitt, 586 U.S. __, 139

S.Ct. 399 (2018).

In United States v. Stitt, 586 U.S. __, 139 S.Ct. 399 (2018), the

Supreme Court held that “burglary” for purposes of 18 U.S.C. §

924(e)(2)(B)(ii) must include burglarizing “a structure or vehicle that has

been adapted or is customarily used for overnight accommodation.” Stitt,

139 S.Ct. at 403-04. At issue therein were two statutes, a Tennessee

burglary statute and an Arkansas burglary statute, both of which

criminalized burglarizing a structure or vehicle that has been adapted or

is customarily used for overnight accommodation. Id. at 404. The Court

held that generic “burglary” for purposes of 18 U.S.C. § 924(e)(2)(B)(ii)

includes such conduct. Id. at 403-04, 407. The Court noted the inherent

9

danger in burglarizing a structure that is customarily used for overnight

accommodation:

[A]t the time the [Armed Career Criminal] Act was

passed. Ibid. In 1986, a majority of state burglary statutes

covered vehicles adapted or customarily used for lodging[.]

(Emphasis added.)

Id. at 406.

For another thing, Congress, as we said in Taylor [v. United

States], viewed burglary as an inherently dangerous crime

because burglary “creates the possibility of a violent

confrontation between the offender and an occupant,

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

. An offender who breaks into a mobile home, an RV, a

camping tent, a vehicle, or another structure that is adapted

for or customarily used for lodging runs a similar or greater

risk of violent confrontation. (Emphasis added.)

Id.

Although, as respondents point out, the risk of violence is

diminished if, for example, a vehicle is only used for lodging

part of the time, we have no reason to believe that Congress

intended to make a part-time/full-time distinction. After all, a

burglary is no less a burglary because it took place at a

summer home during the winter, or a commercial building

during a holiday. (Emphasis added.)

Id.

The Stitt Court went on to distinguish its holding from its previous

holdings in Taylor v. United States, 495 U.S. 575 (1990) and Mathis v.

10

United States, 136 S.Ct. 2243 (2016) having to do with structures used

only for storage:

In Taylor . . . we referred to a Missouri breaking and entering

statute that among other things criminalized breaking and

entering “any boat or vessel, or railroad car.” . . . We did say

that that particular provision was beyond the scope of the

federal Act. But the statute used the word “any”; it referred to

ordinary boats and vessels often at sea (and railroad cars

often filled with cargo, not people), nowhere restricting its

coverage, as here, to vehicles or structures customarily used

or adapted for overnight accommodation. (Emphasis added.)

Stitt, 139 S.Ct. at 407.

In Mathis, we considered an Iowa statute that covered “any

building, structure, . . . land, water or air vehicle, or similar

place adapted for overnight accommodation of persons [or

used] for the storage or safekeeping of anything of

value.” Courts have construed that statute to cover ordinary

vehicles because they can be used for storage or safekeeping.

. . . That is presumably why, as we wrote in our opinion, “all

parties agree[d]” that Iowa’s burglary statute “covers more

conduct than generic burglary does.”

...

[T]he Court in Mathis did not decide the question now before

us—that is, whether coverage of vehicles designed or adapted

for overnight use takes the statute outside the generic

burglary definition. (Emphasis added.)

Stitt, 139 S.Ct. at 407.

Texas courts however have upheld burglary convictions in each of

the following cases, none of which involved a structure adapted or is

customarily used for overnight accommodation: Warren v. State, 2020

11

Tex. App. LEXIS 2473, at *6-7, 9 (Tex. App.—Tyler 2020, pet. ref’d)

(unpublished) (defendant stole the victim’s lawn mower from the victim’s

backyard storage shed); Ellett v. State, 607 S.W.2d 545, 548-49 (Tex.

Crim. App. 1980) (defendant entered former hotel that had been closed

for years and was being used for storage, and had broken-out and boarded

windows; Court stated, "We hold that ‘storage’ constitutes a ‘use’ within

the scope of Sec. 30.01[.]”); Wilson v. State, 1998 Tex. App. LEXIS 6044,

at *4-5 (Tex. App.—Dallas 1998) (unpublished) (Defendant took show

horse bridles from tack room in victim’s barn); Ysassi v. State, 1998 Tex.

App. LEXIS 3459, at *5-6 (Tex. App.—Dallas 1998, no pet.) (unpublished)

(Defendant stole gardening tools from a structure attached to a nursery

used for storing fertilizer, chemicals and tools); Batiste v. State, 1993

Tex. App. LEXIS 3020, at *1, 6 (Tex. App.—Houston [1st Dist.] 1993, no

pet.) (Defendant stole lawn mower from detached garage at the end of a

long driveway, the garage being used to park the family’s cars and to

store tools); In re J.T., 824 S.W.2d 671, 673 (Tex. App.—Fort Worth 1992,

no pet.) (Defendant stole fireworks from a fireworks stand, “a small little

house built on a trailer.”); Frizzell v. State, 1987 Tex. App. LEXIS 8318,

at *3 (Tex. App.—Houston [14th Dist.] 1987, no pet.) (unpublished)

12

(Defendant attempted to take a welding machine inside a storage

building); Allen v. State, 719 S.W.2d 258, 259 (Tex. App.—Waco 1986, no

pet.) (Defendant stole tires from a trailer used to store auto supplies and

tires); Lopez v. State, 660 S.W.2d 592, 594 (Tex. App.—Corpus Christi

1983, pet. ref’d) (Defendant stole tools from locked office in a radiator

shop); See also Kemp v. State, 2020 Tex. App. LEXIS 2506, at *5-9 (Tex.

App.—Fort Worth Mar. 26, 2020, no pet.) (unpublished) (Defendant on

trial for burglary of a habitation was entitled an instruction on the lesser

included offense of burglary of a building, given that the structure

appeared to be used only for storage; “brimming with trash bags, boxes,

and bins full of goods.”); Bryan v. State, No. 04-22-00757-CR, 2023 Tex.

App. LEXIS 8609, at *1 (Tex. App.—San Antonio Nov. 15, 2023, no pet.

h.) (unpublished) (“Skipper Jerome Bryan, Jr. entered an open plea of

guilty to burglary of a building, and the evidence established that he

entered a storage unit that did not belong to him and stole items.”);

Gomez v. State, No. 11-21-00236-CR, 2023 Tex. App. LEXIS 3582, at *12 (Tex. App.—Eastland May 25, 2023, pet. ref'd) (unpublished)

(Defendant entered a storage building and was preparing to steal comic

books and vinyl records when caught); Davidson v. State, Nos. 03-20-

13

00146-CR, 03-20-00147-CR, 2021 Tex. App. LEXIS 5033, at *19 (Tex.

App.—Austin June 24, 2021, no pet.) (unpublished) (Defendant stealing

clothes from laundry facility); Deanda v. State, No. 13-20-00022-CR, 2021

Tex. App. LEXIS 1833, at *3 (Tex. App.—Corpus Christi Mar. 11, 2021,

no pet.) (unpublished) (Water heater stolen from utility building).

According to Stitt, generic burglary requires evidence that the

structure under consideration has “been adapted or is customarily used

for overnight accommodation.” Stitt, 139 S.Ct. at 403-04. If the statute at

issue criminalizes burglarizing a structure that is only used for storage,

safekeeping, or cargo, the statute criminalizes conduct outside the

generic definition of burglary. Id. at 407.

Conclusion

For the foregoing reasons, Petitioner Schorovsky respectfully urges

this Court to grant a writ of certiorari to review the opinion of the United

States Court of Appeals for the Fifth Circuit.

14

Respectfully submitted,

/s/ John A. Kuchera

JOHN A. KUCHERA

210 N. 6th St.

Waco, Texas 76701

(254) 754-3075

(254) 756-2193 (facsimile)

johnkuchera@210law.com

SBN. 00792137

Attorney for Petitioner

Certificate of Service

This is to certify that a true and correct copy of the above and

foregoing Petition for Writ of Certiorari has this day been mailed by the

U.S. Postal Service, First Class Mail, to the Solicitor General of the

United States, Room 5614, Department of Justice, 10th Street and

Constitution Avenue, N.W. Washington, D.C. 20530.

SIGNED this 26th day of June, 2024.

/s/ John A. Kuchera

John A. Kuchera,

Attorney for Petitioner Richard Schorovsky

15

Appendix A

Appendix B

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