Estremera v. United States, No. 17-831 (2d Cir. 2019)Annotate this Case
Petitioner's prior Connecticut state convictions for first and second degree robbery categorically qualify as violent felonies under the force clause of the Armed Career Criminal Act (ACCA). The Second Circuit affirmed the district court's denial of petitioner's motion to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. In Shabazz v. United States, 912 F.3d 73 (2d Cir. 2019), the court held that Connecticut's simple robbery statute qualifies as a violent felony under the force clause. The court explained that the statutes under which petitioner was convicted require that he have committed simple robbery. The court found petitioner's remaining arguments were without merit.