United States v. Brown, No. 14-11502 (11th Cir. 2015)
Annotate this CaseDefendant, convicted of being a felon in possession of a firearm, appealed his sentence after the district court applied certain enhancements under the Armed Career Criminal Act, 18 U.S.C. 924(e). The court concluded that the district court correctly determined that felony obstruction under Georgia law is categorically a violent felony for purposes of the ACCA’s elements clause; even counting defendant’s prior cocaine convictions as a single offense for purposes of the ACCA, his record still would have included three qualifying predicate offenses - two convictions for felony obstruction and a conviction for selling cocaine; because the district court’s treatment of defendant’s cocaine convictions did not affect his status as an armed career criminal, it did not affect his advisory guidelines range or sentence; and his sentence of 210 months in prison is substantively reasonable. Accordingly, the court affirmed the sentence.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.