United States v. Steward, No. 16-3886 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's sentence, holding that defendant's previous conviction for Oklahoma voluntary manslaughter qualified as a crime of violence under both versions of the Guidelines (2015 and 2016). In this case, defendant was convicted of sex trafficking of a child and sentenced as a career offender. The court explained that the Oklahoma voluntary manslaughter satisfied the generic definition of manslaughter. Furthermore, there was no Ex Post Facto Clause issue as to defendant's sentence and he was properly sentenced as a career offender.
Court Description: Kelly, Author, with Colloton and Benton, Circuit Judges] Criminal case - Sentencing. The district court did not err in determining that defendant's Oklahoma voluntary manslaughter conviction qualified as a crime of violence under the 2015 Guidelines; the offense also qualified as a crime of violence under the 2016 Guidelines; because the offense qualified as a crime of violence under both versions of the Guidelines (the one in effect when defendant committed the instant offense and the one in effect at the time of his sentencing), there was no Ex Post Facto Clause issue as to application of the 2016 Guidelines, and defendant was properly sentenced as a career offender.
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