United States v. Clark, No. 20-1506 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of being a felon in unlawful possession of ammunition. The court concluded that defendant's prior conviction for aggravated battery of a peace officer in violation of 720 Ill. Comp. Stat. 5/12-3.05(d)(4) and two separate felony convictions for causing willful injury in violation of Iowa Code 708.4(2) qualified as violent felonies for purposes of sentencing under the Armed Career Criminal Act (ACCA).
The court concluded that the district court did not err in relying on the proffered Shepard documents to conclude that defendant's Illinois conviction for aggravated battery of a peace officer was based on the "causes bodily harm" alternative and was therefore a violent felony conviction under the ACCA's force clause. The court also concluded that both of defendant's willful injury convictions were Class D felony violations of section 708.4(2), which requires that a person actually "causes bodily injury to another." Therefore, defendant was convicted of offenses requiring violent, physical force as an element.
Court Description: [Loken, Author, with Grasz and Kobes, Circuit Judges] Criminal case - Sentencing. Defendant's Illinois aggravated battery conviction and his Iowa willful injury convictions qualified as violent felonies for purposes of sentencing under the Armed Career Criminal Act.
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