United States v. Soileau, No. 11-3552 (8th Cir. 2012)
Annotate this CaseDefendant pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court determined Defendant had four prior convictions that qualified as violent felonies, and thus he was subject to the enhanced sentencing provisions of the Armed Career Criminal Act (ACCA). Defendant appealed the enhanced ACCA sentence. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly used a modified categorical approach in looking to the charging documents, plea agreement, and change of plea documents; (2) the charging documents contained sufficient information to show the convictions qualified as violent felonies; and (3) thus, because Defendant committed at least three prior violent felonies, the district court properly sentenced him as an armed career criminal.
Court Description: Criminal case - Sentencing. District court properly applied the modified categorical approach in looking to the charging documents, plea agreement and change of plea documents to determine whether defendant's prior state court convictions qualified as a predicate offenses for application of the Armed Career Criminal Act; material contained sufficient information to determine the convictions qualified as violent felonies.
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