United States v. Wurie, No. 15-1395 (1st Cir. 2017)Annotate this Case
The First Circuit affirmed the sentence imposed by the district court for Defendant’s conviction of distribution of five grams or more of cocaine base. On appeal, Defendant challenged the classification of his prior Massachusetts convictions as crimes of violence under the residual clause of section 4B1.2(a)(2) of the United States Sentencing Guidelines. Defendant’s prior convictions included assault and battery with a dangerous weapon (ABDW, resisting arrest, larceny from the person, and assault and battery on a police officer. The First Circuit held that under the Guidelines’ residual clause, Defendant’s ABDW convictions were for crimes of violence, and therefore, Defendant was correctly sentenced as a career offender.