United States v. Rangel-Castaneda, No. 12-4408 (4th Cir. 2013)Annotate this Case
Defendant appealed the district court's holding that his Tennessee statutory rape conviction qualified as a generic "statutory rape" offense and thus constituted a "crime of violence" under the sentencing enhancement established in U.S.S.G. 2L1.2(b)(1)(A)(ii). Because Tennessee's statutory rape provision set the age of consent at eighteen and was therefore significantly broader than the generic offense, the court held that a conviction thereunder did not categorically qualify for the crime-of-violence enhancement. Accordingly, the court reversed and remanded.