McCoy v. United States, No. 16-3953 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit held that voluntary manslaughter under 18 U.S.C. 1112 qualifies as a crime of violence under the force clause of 18 U.S.C. 924(c)(3)(A) because it has an element of force against the person of another. The court affirmed the district court's judgment, holding that there is no material difference between the force clause at issue in United States v. Fogg, 836 F.3d at 956, and the force clause under section 924(c)(3)(A).
Court Description: [Colloton, Author, with Beam and Kelly, Circuit Judges] Prisoner case - Habeas. Voluntary manslaughter under 18 U.S.C. Section 1112 qualified as a crime of violence under the force clause of 18 U.S.C. Section 924(c)(3)(A) because it has an element of force against the person of another. Judge Kelly, concurring in the judgment.
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