United States v. Irons, No. 16-1998 (8th Cir. 2017)
Annotate this CaseDefendant appealed his sentence after he was convicted of unlawful possession of a firearm. The court concluded that the district court appropriately used the modified categorical approach in determining that defendant's 2012 conviction of committing violence against another inmate, in violation of Mo. Rev. Stat. 217.385, subd. 1, was a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The court reasoned that because the Missouri conviction was a predicate felony under the ACCA, it was also a crime of violence under the Sentencing Guidelines. Accordingly, the court affirmed the sentence.
Court Description: Wright, Author, with Wollman and Smith, Circuit Judges] Criminal case - Sentencing. The district court did not err in determining that defendant's conviction for violence against another inmate in violation of Mo. Rev. Stat. Section 217.385, subd. 1, was a predicate violent felony for purposes of sentencing under the Armed Career Criminal Act; the district court did not err in using the modified categorical approach in reaching this determination; because the offense was a predicate violent felony under the Act, it was also a crime of violence for purposes of Guidelines Sec. 4B1.2(a)(1).
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