Douglas v. United States, No. 17-1104 (7th Cir. 2017)
Annotate this CaseDouglas pleaded guilty as a felon possessing a firearm, 18 U.S.C. 922(g)(1). The judge found that at least three of Douglas’s 16 other felony convictions were “violent felonies” under the Armed Career Criminal Act, 18 U.S.C. 924(e). After the Supreme Court found, in “Johnson,” the residual clause of section 924(e)(2)(B)(ii) unconstitutionally vague, Douglas unsuccessfully sought a sentence reduction. The Seventh Circuit affirmed. Johnson concerns only a part of 924(e)(2)(B)(ii). The elements clause, 924(e)(2)(B)(i), applied by the district court to Douglas's convictions, remains in effect. Class C felony battery in Indiana at the time of those convictions required that a person “knowingly or intentionally touches another person in a rude, insolent, or angry manner,” which “results in serious bodily injury to any other person.” The Supreme Court has stated that the sort of force that comes within the elements clause is “force capable of causing physical pain or injury to another person.” The Indiana statute had “serious bodily injury” as an element. Douglas did not cite any decision in which Indiana’s courts have convicted someone of Class C felony battery after a light touch resulted in serious injury. All the cited cases involved violent force. Intent to use force was an element of the offense, satisfying the elements clause.
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