United States v. Baker, No. 10-1925 (2d Cir. 2012)Annotate this Case
Defendant was convicted of possessing a firearm and sentenced to a mandatory minimum of 15 years' imprisonment. On appeal, defendant challenged the district court's determination that he had three or more prior convictions for felonies categorized as "violent" under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), and that he was subject to the ACCA mandatory minimum sentence as a result. The court held that defendant's convictions for escape from custody qualified as violent felonies. Therefore, the district court did not err in imposing the ACCA's mandatory minimum sentence.