Howard was convicted of being a felon in possession after officers found a stolen pistol in the glove compartment of his car, which he had been driving. The district court applied the ACCA based on one robbery and two of Howard’s seven Alabama third-degree burglary convictions that the government documented, and imposed a 235-month sentence. The Eleventh Circuit affirmed the firearm conviction because the car’s ownership, the tag receipt and pistol in its glove compartment, Howard’s recent control of the car, and his prior firearm conviction supported constructive possession. Applying Descamps, the court concluded that the statute’s definition of “building” extended beyond the generic burglary offense and that its listed locations were examples, not alternative elements. No conviction under that statute could therefore qualify as generic burglary under the ACCA; the court did not reach Howard’s alternative argument that the Shepard documents failed to establish the burglary elements. The court vacated the sentence and remanded for resentencing without the ACCA enhancement; on Howard’s unopposed request, it barred the government from arguing that his prior convictions qualified under the ACCA residual clause, while allowing the district court to consider his criminal history under 18 U.S.C. § 3553(a).