United States v. Adams, No. 11-3707 (7th Cir. 2012)
Annotate this CaseAdams was sentenced, in Illinois, to 180 days in jail plus three years’ probation for a 1981 armed robbery; he committed a second robbery while on probation. He was convicted of robbery and aggravated battery. Paroled in August, 1984, he promptly violated, but was re-paroled in December. He committed another armed robbery in January 1985 and was sentenced to 25 years. While confined, Adams committed aggravated battery of a guard. He had not been out for long when he was caught with a firearm, convicted as a felon in possession, 18 U.S.C. 922(g), and sentenced to 15 years’ imprisonment as an armed career criminal, 18 U.S.C. 924(e). Adams conceded that two convictions qualify as violent felonies but argued that two do not, given 18 U.S.C.921(a)(20), which provides that restoration of civil rights causes a conviction to be disregarded for federal felon-in-possession statutes. The Seventh Circuit affirmed. In 1984 Illinois repealed statutes that had allowed criminals to possess firearms beginning five years after release from prison; his civil right to possess firearms was not restored and that right would not have been restored even under the pre-1984 version of Illinois law, since he has not spent any five-year period out of prison.
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