United States v. Libby, No. 17-1023 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), holding that defendant's previous conviction for Minnesota first degree robbery was a violent felony and a predicate offense under the ACCA. The court reasoned that Minnesota's express requirement that a defendant communicate a threat to overcome resistance or to compel acquiescence necessarily implicated the use of violent force.
Court Description: Goldberg, Author, with Wollman and Shepherd, Circuit Judges] Criminal case - Sentencing. Defendant's conviction for first degree aggravated robbery in violation of Minn. Stat. Sec. 609.245, subd. 1 was a violent felony and a predicate offense for Armed Career Criminal Act sentencing.
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