United States v. Byas, No. 16-3616 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit vacated defendant's sentence after he was convicted of being a felon in possession of a firearm. The court held that defendant's prior conviction for burglary under the Illinois statute used a broader definition of "building" than Taylor v. United States, 495 U.S. 575 (1990), and thus defendant's conviction did not qualify as a predicate offense under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). Accordingly, the court remanded for resentencing.
Court Description: Per Curiam - Before Loken, Beam and Shepherd, Circuit Judges] Criminal case - Sentencing. The relevant Illinois statute uses a broader definition of a "building" than Taylor v. United States, 495 U.S. 575 (1990) and therefore defendant's conviction for violating 720 Ill. Comp. Stat. 5.19-1(a) does not qualify as a predicate offense for ACCA sentencing; reversed and remanded for further proceedings.
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