United States v. Williams, No. 22-6021 (10th Cir. 2023)
Annotate this CaseDefendant Brandon Williams pled guilty to being a felon in possession of a firearm, and was sentenced to 180 months’ imprisonment. On appeal, he challenged his lengthy sentence as an improper application of the Armed Career Criminal Act (ACCA). He claimed that his two prior Arkansas drug convictions were not categorically “serious drug offenses” under 18 U.S.C. § 924(e)(2)(A)(ii) because his state convictions could have applied to hemp, and hemp was no longer a federally controlled substance at the time of his federal sentencing. Since there was a categorical match between Arkansas’ definition of marijuana at the time of Williams’ prior convictions and the federal definition at the time he committed his federal offense, the Tenth Circuit determined the district court properly applied the ACCA enhancement.
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