United States v. Coleman, No. 19-3119 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that, although defendant's prior Missouri conviction is not a predicate offense under the Armed Career Criminal Act, his 2003 conviction for possession of cocaine for resale, in violation of Tenn. Code Sec. 39-17-417(a)(4), was a serious drug offense for purposes of applying the ACCA enhancement. Therefore, defendant had the three requisite convictions that the ACCA requires.