ACCA

United States v. John Terry Chatman, Jr. (8th Cir. March 2020)

The Court reversed the defendant's conviction for obstruction of justice by attempting to kill a witness where the evidence showed that the defendant shot at an officer "out of frustration and retaliation" and not with the intent of "preventing a communication about the commission of a federal offense" to other other officers.

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Shular v. United States (U.S. Supreme Court, February 2020)

In a unanimous decision, the Supreme Court held a defendant's prior conviction under state law qualifies as a "serious drug offense" under the ACCA if the defendant's conduct involves "manufacturing, distributing, or possessing with intent to manufacture or distribute, a controlled substance" as spelled out under the statute. In doing so, the Court rejected a categorical approach that would require courts to match the defendant's state offenses to a "generic offense."

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United States v. William Dale Wooden (6th Cir. December 2019)

The Court held that the defendant's consent for an undercover officer to enter his house was not tainted by "police deception." While the officer did not identify himself as law enforcement to the defendant when he asked to talk to the defendant's wife and to step inside "to get out of the cold," the officer did not take any affirmative acts to conceal his identity from the defendant. The Court also held that Wooden’s burglary convictions under Georgia law qualified as crimes of violence under the ACCA.

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United States v. Tyrone Mitchell (3rd Cir. December 2019)

The Court held that the sentencing court committed plain and reversible error when it relied on the defendant’s “bare arrest record” in determining a sentence, as the sentencing court had only cited the Defendant’s “extensive criminal history” without adequately distinguishing between adjudications, convictions, and mere arrests. 

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United States v. Martin Johnson (4th Cir. December 2019)

The Court held that a district court does not plainly err by failing to give a limiting instruction when admitting 404(b) evidence in the absence of a defendant's request for such an instruction. Additionally, the Court held that robbery possession of a controlled substance with intent to distribute under Maryland law are predicate "violent felonies" under the ACCA.

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