United States v. Pate, No. 13-1207 (8th Cir. 2014)
Annotate this CaseDefendant appealed his conviction and sentence for being a felon in possession of a firearm. The court concluded that the evidence was sufficient to convict defendant where a recorded interview supported the imminently reasonable inference that the gun defendant owned and wanted out of the residence was the same gun found by police shortly after his arrest. The court held that a violation of Minnesota Statute 609.487, subd. 3, fleeing an officer in a motor vehicle, presented a serious potential risk of physical injury to another and is therefore a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The court rejected defendant's claim that the ACCA's residual clause is void for vagueness. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law and sentencing. Evidence was sufficient to support defendant's conviction for being a felon in possession of a firearm; Descamps v. U.S., 133 S. Ct. 2276 (2013) does not alter the court's earlier case law that fleeing a police officer in a motor vehicle in violation of Minn. Stat. Sec. 690.487, subd. 3, qualifies as a violent felony under the Armed Career Criminal Act's residual clause; residual clause is not void for vagueness.
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