United States v. Hill, No. 17-2425 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's sentence after he pleaded guilty to unlawful possession of ammunition as a previously convicted felon. The court held that defendant's prior Missouri drug convictions qualified as serious drug offenses under the Armed Career Criminal Act and he therefore had three prior qualifying convictions to be sentenced as an armed career criminal. The court explained that United States v. Bynum, 669 F.3d 880 (8th Cir. 2012), held that a knowing offer to sell drugs in Minnesota is a crime "involving" the distribution of drugs, because it is "related to or connected with" drug distribution.
Court Description: Per Curiam - Before Colloton, Gruender and Grasz, Circuit Judges] Criminal case - Sentencing. The district court did not err in sentencing defendant as an armed career criminal because his prior Missouri drug convictions qualified as serious drug offenses within the meaning of 18 U.S.C. Sec. 924(e)(2)(A)(ii) - see U.S. Bynum, 669 F.3d 880 (8th Cir. 2012).
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