United States v. Bowers, No. 20-2100 (1st Cir. 2022)
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The First Circuit affirmed Defendant's sentence for being a felon in possession of a firearm, holding that the district court did not err in its application of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1) and in its imposition of a mandatory fifteen-year sentence.
Defendant pled guilty to a felon in possession charge. The district court concluded that, due to his four prior Maine burglary convictions, Defendant qualified for the ACCA's enhanced mandatory minimum penalty, and sentenced Defendant to fifteen years' imprisonment. The First Circuit affirmed, holding (1) the district court did not err in applying the ACCA to Defendant based on his prior burglary convictions in Maine; and (2) this Court declines to overturn its prior decision in United States v. Duquette, 778 F.3d 314 (1st Cir. 2015), and its application of the categorical approach to the statute at issue here.
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