United States v. Williams, No. 17-1632 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed defendant's 60 month sentence after he pleaded guilty to firearm offenses. The court held that defendant's New York conviction for attempted second-degree robbery was a crime of violence under the force clause of USSG 4B1.2(a); any error was harmless where the district court considered the 18 U.S.C. 3553(a) sentencing factors and stated that it would have imposed the same sentence regardless of its ruling on the crime of violence issue; the district court did not err by imposing three criminal history points for the offense based on its determination that this was an adult conviction, and any error was harmless; and any error in using the 2015 rather than the 2016 Sentencing Guidelines Manual was harmless because the relevant provisions were identical in the two versions.