United States v. Williams, No. 18-1273 (8th Cir. 2019)
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The Eighth Circuit affirmed Defendants Williams and Jefferson's sentences imposed after they each pleaded guilty to possessing a firearm after being convicted of a felony. The court held that Williams' prior Minnesota conviction for simple robbery qualified as a crime of violence, and his prior conviction for possession of a firearm in furtherance of a drug trafficking crime qualified as a controlled substance offense for purposes of sentencing under USSG 4B1.2(b)cmt. n. 1.
The court also held that Jefferson's within-guidelines sentence was not substantively unreasonable, because it was not unconstitutional and the district court did not abuse its discretion by imposing a three-year term of supervised release.
Court Description: Kelly, Author, with Loken and Colloton, Circuit Judges] Criminal cases - Sentencing.Defendant Williams' Minnesota robbery conviction is a crime of violence under the Guidelines; Williams' federal conviction under 18 U.S.C. Sec. 924(c)(1) was a controlled substance offense for purposes of sentencing under Guidelines Sec. 4B1.2(b)cmt. n. 1.; Defendant Jefferson's within-guidelines sentence was not substantively unreasonable; it was neither unconstitutional nor an abuse of the district court's discretion to impose a three-year term of supervised release for Jefferson.
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