United States v. Lockett, No. 13-2200 (7th Cir. 2015)
Annotate this CaseIn 1981, Lockett pleaded guilty to robbery. In 1982, he violated probation, pleading guilty to unlawful use of a weapon. In 1984, he pleaded guilty to possession of heroin. In 1990, he was pleaded guilty to armed violence, with several counts of distribution and possession with intent to distribute heroin. While on parole, he pleaded guilty to drug offenses; once in 1992 and twice in 1993. In 1998, he pleaded guilty delivery of cocaine. In 2003, he pleaded guilty to attempt to possess a controlled substance. In 2004, Lockett pleaded guilty to burglary. In 2010, Lockett was convicted as a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The parties disagreed over whether a third qualifying conviction under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1) could be based on his 1990 drug convictions. The government argued that because Lockett was subject to an Illinois recidivist enhancement, which increases the maximum penalty, the convictions were qualifying ACCA predicates. The court held that a 1995 restoration of civil rights letter did not apply to Lockett’s 1990 convictions, that they could serve as predicates, and imposed the 15-year minimum sentence. The Seventh Circuit reversed. The court erred in finding that the 1990 drug convictions qualified as predicates because there was no evidence that he actually faced the recidivist enhancement.
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