United States v. Van Mead, No. 12-4054 (2d Cir. 2014)Annotate this Case
Defendant plead guilty to failing to register as a sex offender and possession of stolen firearms. On appeal, defendant challenged his sentence, contending that the district court erroneously applied an enhancement under U.S.S.G. 2K2.1. The court vacated the judgment and remanded for resentencing, concluding that defendant's conviction for statutory rape under New York Penal Law 130.40-2 was not categorically a "crime of violence" under U.S.S.G. 4B1.2.