United States v. Sims, No. 16-1233 (8th Cir. 2017)Annotate this Case
Defendant appealed his conviction after pleading guilty to being a felon in possession of a firearm. The district court imposed a sentencing enhancement pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1), based on defendant's two prior Arkansas residential burglary convictions. The court concluded that the Arkansas residential burglary convictions did not qualify as ACCA predicate felonies because Arkansas residential burglary categorically sweeps more broadly than generic burglary. Accordingly, the court vacated the sentence and remanded for resentencing.