United States v. Jones, No. 15-1518 (2d Cir. 2017)Annotate this Case
The Second Circuit affirmed defendant's sentence of 180 months in prison after he was convicted of assaulting a federal officer. In light of Beckles v. United States, 137 S. Ct. 886 (2017), which held that the residual clause of the Career Offender Guideline—a second basis for finding a crime of violence—was not unconstitutional, the court held that New York first‐degree robbery categorically qualifies as a crime of violence under the residual clause and the court need not address defendant's argument based on the force clause. The court also held that defendant's sentence was substantively reasonable.
This opinion or order relates to an opinion or order originally issued on July 21, 2016.