Harrington v. United States, No. 11-2119 (2d Cir. 2012)Annotate this Case
Harrington is serving a statutorily mandated 15-year prison sentence under the Armed Career Criminal Act, 18 U.S.C. 924(e), on his guilty plea to possession of a firearm by a convicted felon in violation of 18 U.S.C. 922(g)(1). The district court rejected his challenge to the sentence. The Second Circuit affirmed. Harrington’s vagueness challenge to the ACCA was barred because it was not presented to the district court. First degree unlawful restraint under Conn. Gen. Stat. 53a-95, is a violent felony under the ACCA’s residual clause, that together with two prior first-degree robbery convictions compelled imposition of the statutorily mandated minimum 15-year prison term.