United States v. Williams, No. 18-2662 (7th Cir. 2019)
Annotate this CasePolice arrested Williams for selling cocaine, then found a gun in his pocket. After he pleaded guilty to federal firearm and cocaine charges, the government sought a sentencing enhancement under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), which applies if the defendant has three prior convictions for violent felonies or serious drug offenses. The government offered evidence of Williams’ prior convictions for burglary, robbery, and dealing cocaine. For the cocaine conviction, the government established that in 2007, Indiana charged Williams with a Class A Felony for “Dealing Cocaine,” and alleged that Williams knowingly or intentionally delivered cocaine within 1000 feet of a school. Williams pleaded guilty to “the lesser included offense of Dealing Cocaine as a Class B Felony.” The district court applied the ACCA enhancement, finding that Williams’ “Dealing Cocaine” conviction qualified as a predicate “serious drug offense.” Williams did not dispute the presentence report and was subject to a statutory minimum of 15 years in prison. The court calculated a Guidelines range of 210-262 months' imprisonment but found that the range likely overstated the seriousness of Williams’ conduct and sentenced him to 188 months in prison. The Seventh Circuit affirmed, rejecting arguments that the record did not show exactly which statute he was convicted of violating and that Indiana’s statute on dealing cocaine is broader than the ACCA definition of a “serious drug offense.”
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