United States v. Sadler, No. 16-3946 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit affirmed defendant's above-Guidelines sentence of 102 months in prison for being a felon in possession of a firearm. The court held that the district court was permitted to conclude that the Guidelines did not adequately account for defendant's prior criminal history or likelihood to reoffend. The district court also recognized that defendant did not technically qualify as an armed career criminal and its passing remark did not undermine this recognition.
Court Description: Per Curiam - Before Smith, Chief Judge, Colloton and Kelly, Circuit Judges] Criminal case - Sentencing. Defendant's above-guidelines sentence was based on his extensive and violent criminal history, the failure of past sentences to deter his criminal conduct and the need to protect the public; the court's passing remark that defendant was exactly the type of defendant Congress had in mind when it passed the Armed Career Criminal Act did not undermine the court's recognition - on the record - that defendant did not qualify as an armed career criminal under Johnson.
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