United States v. Drummond, No. 18-4197 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's pretrial motion to suppress evidence after he was convicted of possession of a firearm and ammunition by a convicted felon. The court held that the warrant affidavit prepared by an officer was sufficient to establish probable cause for the magistrate to issue the search warrant.
The court also affirmed the district court's imposition of a sentencing enhancement under the Armed Career Criminal Act (ACCA), holding that defendant's prior offense for criminal domestic violence under South Carolina law categorically qualified as violent felonies. Therefore, defendant had the three predicate convictions for purposes of the ACCA.