United States v. Reed, No. 15-1262 (1st Cir. 2016)
Annotate this CaseDefendant pled guilty to one count each of robbery, brandishing of a firearm during and in relation to a crime of violence, and possession of a firearm by a felon subject to the Armed Career Criminal Act’s (ACCA) mandatory minimum sentence. The district court imposed a downwardly variant sentence of 192 months’ imprisonment. Defendant appealed his sentence. The First Circuit affirmed, holding (1) the district court did not err in concluding that Defendant’s prior convictions subjected him to a fifteen-year mandatory minimum sentence under the ACCA; and (2) the district court properly applied a career offender sentencing enhancement under the United States Sentencing Guidelines.
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