United States v. Manzanares, No. 18-2010 (10th Cir. 2020)
Annotate this CaseDefendant-Appellant Archie Manzanares appealed a district court’s denial of his 28 U.S.C. 2255 motion challenging his sentence under the Armed Career Criminal Act (ACCA). Under the ACCA, an offense qualified as a violent felony by satisfying at least one of three definitions, which have come to be known as the Elements Clause, the Enumerated Clause, and the Residual Clause. Manzanares asserted that without the Residual Clause, his underlying New Mexico convictions (armed robbery, aggravated assault with a deadly weapon, and aggravated battery) no longer qualified as violent felonies. The district court denied the motion, concluding that all three underlying convictions satisfied the Elements Clause. Manzanares appealed the classification of the armed robbery conviction as a violent felony to the Tenth Circuit, and sought to expand the certificate of appealability to allow him to appeal the decision regarding the aggravated assault with a deadly weapon and aggravated battery convictions. After review, the Tenth Circuit affirmed the district court’s denial of Manzanares’s 2255 motion, and denied his motion to expand the COA.
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