United States v. Allred, No. 18-6843 (4th Cir. 2019)Annotate this Case
The Fourth Circuit reversed the district court's grant of defendant's 28 U.S.C. 2255 motion challenging his sentence as no longer valid. The court held that defendant's predicate conviction for causing bodily injury to a witness under 18 U.S.C. 1513(b)(1) is categorically a violent Armed Career Criminal Act (ACCA) felony. In this case, defendant's conviction required knowing conduct that causes bodily injury to another, which categorically involved the use of violent force sufficient to bring it within the ACCA's elements clause.