United States v. Robinson, No. 21-1622 (7th Cir. 2022)
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Robinson, whose criminal career began in 1991, pleaded guilty, without a plea agreement, to being a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The court granted Robinson an acceptance-of-responsibility reduction to his offense level but, after Robinson argued that he should not be classified as an armed career criminal under the Armed Career Criminal Act (ACCA) 18 U.S.C. 924(e), revoked that reduction. It then found that Robinson was an armed career criminal, subject to a mandatory minimum sentence of 180 months. The Seventh Circuit vacated his 188-month sentence. On remand, the district court sentenced Robinson to the 180-month statutory minimum.
While Robinson’s second appeal was pending, the Supreme Court (Borden, 2021) addressed the meaning of “use … of physical force against the person of another” in ACCA section 924(e)(2)(B). Robinson argued that his 1992 Illinois conviction for aggravated discharge of a firearm no longer qualified as an ACCA predicate offense. The Seventh Circuit affirmed, noting that Robinson’s ACCA status was settled at his initial sentencing proceeding and remains settled after Borden. The mens rea for Illinois’s aggravated-discharge offense is knowledge, not recklessness; Borden is irrelevant to Robinson’s status because his predicate violent offense was not a reckless crime.
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