United States v. Kyle Boleyn, No. 17-3817 (8th Cir. 2019)
Annotate this CaseA prior conviction under Iowa Code 124.401, which makes it unlawful to manufacture, deliver or possess with intent to manufacture or deliver, a controlled substance, qualifies as a predicate offense warranting sentence enhancements under the Armed Career Criminal Act (ACCA), the Controlled Substances Act (CSA), and the career offender provisions of the Sentencing Guidelines. The court held that the Iowa law of aiding and abetting is substantially equivalent to, not meaningfully broader than, the standard adopted by federal courts in applying 18 U.S.C. 2 and urged by defendants in these appeals. Accordingly, the district courts properly applied the sentencing enhancements in these consolidated cases.
Court Description: Loken, Author, with Grasz and Stras, Circuit Judges] Criminal case - Sentencing. These five appeals raise a common issue: whether a prior conviction under Iowa Code 124.401, which makes it unlawful to manufacture, deliver or possess with intent to manufacture or deliver, a controlled substance, qualifies as a predicate offense warranting sentencing enhancements under the Armed Career Criminal Act, the Controlled Substances Act, and the career offender provisions of the Sentencing Guidelines if the Iowa law of aiding and abetting is overly broad. Held: the convictions do qualify as predicate offenses under the ACCA, the CSA and the Guidelines; the Iowa law of aiding and abetting is substantially equivalent to, not meaningfully broader than, the standard adopted by federal courts in applying 18 U.S.C. Sec. 2.
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