USA v. Eugene Jackson, No. 21-13963 (11th Cir. 2022)
Annotate this Case
Defendant pled guilty to possession of a firearm and ammunition by a convicted felon, Sections (1) and 924(e)(1). In support of his guilty plea, the factual proffer shows that he unlawfully possessed a loaded firearm on September 26, 2017. Although Defendant conceded that he had two prior convictions that satisfy ACCA’s definition of a “violent felony,” he objected to the probation officer’s conclusion that his two cocaine-related convictions met ACCA’s “serious drug offense” definition. But the district court overruled Defendant’s objection, finding that his cocaine-related convictions did qualify and sentenced Defendant to ACCA’s mandatory fifteen-year minimum. Defendant appealed his sentence.
The Eleventh Circuit affirmed. The court concluded that ACCA’s definition of a state “serious drug offense” incorporates the version of the federal controlled substances schedules in effect when Defendant was convicted of the prior state drug offense. The court explained that when possible, the court interprets the provisions of a text harmoniously. To read the definition in Section 924(e)(2)(A)(ii) harmoniously with the rest of Section 924(e)’s subparts, the court wrote it must read that definition to incorporate the version of the federal controlled-substances schedules in effect when Defendant’s prior state convictions occurred. Thus, the court concluded that ACCA’s “serious drug offense” definition encompasses a prior state offense that involved “manufacturing, distributing, or possessing with intent to manufacture or distribute” ioflupane, “for which a maximum term of imprisonment of ten years or more is prescribed by law. Finally, the court wrote that Defendant suggested no other reason why Section 893.13(1) might be categorically broader than ACCA’s definition of a “serious drug offense.”
This opinion or order relates to an opinion or order originally issued on June 10, 2022.
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.