United States v. Bates, No. 18-12533 (11th Cir. 2020)
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The Eleventh Circuit affirmed defendant's conviction and sentence for possession with intent to distribute marijuana, assaulting a federal officer, discharging a firearm in relation to a crime of violence, and being a felon in possession of a firearm.
The court joined five sister circuits and held that an assault conviction in violation of 18 U.S.C. 111(b) qualifies as a crime of violence under 18 U.S.C. 924(c); the district court did not abuse its discretion by excluding evidence relevant to defendant's self-defense theory at trial; the evidence was sufficient to support defendant's conviction on the section 111 and 924(c) counts; defendant's prior Georgia convictions for possession with intent to distribute marijuana qualified as predicate offenses for both the Armed Career Criminal Act and the Sentencing Guidelines; the district court did not clearly err in denying defendant a two-level sentencing reduction for acceptance of responsibility by pleading guilty to the possession charges; defendant's 360-month sentence was substantively reasonable and the district court did not abuse its discretion; and Rehaif v. United States, 139 S. Ct. 2191 (2019), does not require vacating defendant's conviction for possessing a firearm as a felon.
The court issued a subsequent related opinion or order on May 28, 2020.
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