Firearm Offenses

The Federal Docket

Irma Ovalles v. United States (11th Cir. October 2018)

On remand after the Court’s en banc decision in Ovalles, the panel held that Ms. Ovalles’s attempted car-jacking was a “crime of violence” under § 924(c)(3)(A)’s elements clause, as it requires that a defendant have an intent to cause death or bodily harm and that he take a substantial step towards commission of that crime.

Irma Ovalles v. United States (11th Cir. 2018), EN BANC

The Court held that the residual clause of § 924(c), which defines a “crime of violence,” was not void-for-vagueness after invoking the canon of constitutional doubt to support a narrower reading of the provision, one that qualifies a defendant’s offense as a “crime of violence” based on the defendant’s underlying conduct in that offense.

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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