United States v. Enoch, No. 16-1546 (7th Cir. 2017)
Annotate this CaseEnoch pleaded guilty to robbing a person having custody of property belonging to the United States, 18 U.S.C. 2114(a) and brandishing a firearm in relation to a crime of violence, 18 U.S.C. 924(c)(1)(A)(ii). He reserved his right to appeal the district court’s ruling that the former offense qualified as a crime of violence, rendering his brandishing a gun in connection with that offense a separate crime that required a consecutive sentence. Enoch’s sentence (total 108 months) increased significantly because the court considered the conviction under section 2114(a) to be a crime of violence. The Seventh Circuit affirmed. Applying the “categorical approach,” the court stated that the underlying crime of robbing another of government property “has as an element the use, attempted use, or threatened use of physical force against the person or property of another.”
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