United States v. Nathaniel Capler, No. 08-3975 (7th Cir. 2011)
Annotate this CaseAfter selling cocaine to a police informant, the defendant pled guilty to two counts of distribution and was sentenced to 141 months. The district court designated him as a career offender. He had prior Illinois convictions for delivery of a controlled substance and for unlawful restraint. The Seventh Circuit affirmed, holding that unlawful restraint was a "crime of violence" for purposes of the sentencing guidelines. While the Illinois definition of the crime does not require use or threat of force and unlawful restraint is not specifically listed in the sentencing guidelines, the elements of the offense ordinarily involve conduct that is roughly similar to other listed crimes.
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