ACCA

The Federal Docket

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. 

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.

Jimmy Lee Boston v. United States (11th Cir. September 2019)

The Court affirmed the defendant’s sentence under the ACCA, holding that a Florida conviction for aiding and abetting an armed robbery counts as a “violent felony” for purposes of sentencing a defendant under the ACCA since an aider and abettor is liable as a principal under Florida law.

United States v. Davis (U.S. Supreme Court, June 2019)

The Supreme Court struck down the residual clause of 18 U.S.C. § 924(c), which criminalizes carrying a firearm in connection with a “crime of violence” or drug trafficking crime, as unconstitutionally vague. The decision was based on prior Supreme Court decisions striking down similar provisions defining “crimes of violence” under 18 U.S.C. § 16 and the ACCA.

Quarles v. United States (U.S. Supreme Court, June 2019)

The Supreme Court unanimously held that the defendant’s 2002 Michigan conviction for third-degree home invasion was a “violent felony” under the Armed Career Criminal Act’s enumerated-offenses clause, as the Michigan offense “substantially corresponded to” or was narrower than generic burglary under the categorical approach from Taylor v. United States.

United States v. Terin Moss (11th Cir. April 2019)

The Court vacated the defendant’s sentence after holding that a prior conviction under Georgia’s aggravated assault statute is not a “crime of violence” under the ACCA or Federal Sentencing Guidelines when the conviction is based on a simple assault with a mens rea of recklessness.

United States v. Lonnie Anthony Jones (11th Cir. October 2018)

The Court affirmed the defendant’s sentence after holding that defendant’s prior second-degree murder conviction was a “violent felony” under the ACCA’s elements clause.

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