Taylor v. United States, 495 U.S. 575 (1990), was a U.S. Supreme Court decision that filled in an important gap in the federal criminal law of sentencing.
Throughout the legislative process, Congress consistently focused on "career offenders" — "those who commit a large number of fairly serious crimes as their means of livelihood and who, because they possess weapons, present at least a potential threat of harm to persons."
In this way, Congress could avoid leaving the precise contours to the vagaries of varying definitions and labels crafted by other jurisdictions.
In light of these concerns, the Court rejected the Eighth Circuit's approach, which relegated the definition to state law.
For instance, most states allow entry without "breaking," allow burglary to occur during the daytime, and require no felonious intent once inside.
Before the Court, Taylor proposed a definition that defined "burglary" to include only "entering a building of another with the intent to commit a crime that has as an element conduct that presents a serious risk of physical injury to another."
This left a "generic" meaning of the word "burglary" — an unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime.
The final step in the Court's analysis was to settle the question of how to prove whether a particular defendant's conviction qualifies as "generic burglary."
If the state statute is narrower, then "there is no problem, because the conviction necessarily implies that the defendant has been found guilty of all the elements of generic burglary."
"The examination [of the legislative history] does not uncover anything useful (i.e., anything that tempts us to alter the meaning we deduce from the text anyway), but that is the usual consequence of these inquiries (and a good thing, too)."
"I can discern no reason for devoting 10 pages of today's opinion to legislative history, except to show that we have given this case close and careful consideration.