How have courts interpreted the term "burglary" in the criminal code?

The district court rejected both arguments and chose to rely on United States v. Patterson, 882 F.2d 595 (1st Cir.1989), cert. denied, --- U.S. ----, 110 S.Ct. 737, 107 L.Ed.2d 755 (1990). There, the first circuit declined to adopt any particular interpretation because of its uncertainty as to congressional intent about the meaning of the term "burglary". Id. at 604. Instead, it held that a conviction for breaking and entering constituted a violent felony for purposes of enhancement under the "catch-all" clause of the provision. Id.