United States v. Ronning, No. 20-2788 (8th Cir. 2021)
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The Eighth Circuit affirmed defendant's 180 month sentence imposed after he pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court calculated defendant's Sentencing Guidelines offense level as 30 and his criminal history category as VI, which yielded a sentencing range of 180-210 months. However, the district court ruled that defendant's five prior convictions qualified as predicate convictions under the Armed Career Criminal Act (ACCA).
The court rejected defendant's contention that the ACCA violates his equal protection rights and concluded that defendant has not presented any proof of a discriminatory intent or purpose in the enactment of the ACCA or its application to his case. As to defendant's claim regarding differing treatment of juvenile convictions, the court concluded that defendant's predicate convictions do not include any "acts of juvenile delinquency" under the ACCA. The court also concluded that, even if defendant's Wisconsin robbery conviction does not qualify as a predicate offense, defendant's remaining convictions were sufficient to apply the ACCA. Finally, the court concluded that there was no error in denying defendant's request for credit for time served on a prior conviction, and he provided no proof for his claim that the government improperly delayed bringing charges against him.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Grasz, Circuit Judge] Criminal case - Sentencing. Claim that Armed Career Criminal Act sentencing violated defendant's equal protection rights because it has a disparate impact on non-white defendants rejected in the absence of any proof of a discriminatory intent or purpose in enacting the law or in its application to his case either before the district court or this court; none of the convictions used as predicates for application of the Act were juvenile convictions and defendant's argument that the Act has a disparate impact on juvenile convictions is rejected; even if the court agrees that defendant's Wisconsin robbery conviction does not qualify as an ACCA predicate offense, he still had the three convictions necessary to apply the Act; the district court did not err in denying defendant's request for credit for time served on a prior state conviction; defendant provided no proof for his claim the government improperly delayed bringing the charges against him. [ July 28, 2021 ]
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