United States v. Mendoza-Padilla, No. 15-10051 (9th Cir. 2016)
Annotate this CaseAfter defendant pled guilty to one count of illegal reentry after deportation, the district court applied a sixteen-level sentencing enhancement to defendant's base offense level because of his prior manslaughter conviction under Florida law. The court held that, in light of United States Supreme Court guidance, manslaughter, as defined by Florida Statute 782.07, does not constitute a crime of violence under USSG 2L1.2(b)(1)(A). Under Florida's jurisprudence, manslaughter, which does not require a mens rea of at least recklessness, punishes more than only generic contemporary manslaughter. Accordingly, the court vacated the sentence and remanded for resentencing.
Court Description: Criminal Law. Vacating a sentence and remanding for resentencing, the panel held that manslaughter, as defined by Florida Statute § 782.07, does not constitute a crime of violence under U.S.S.G. § 2L1.2(b)(1)(A) because Florida manslaughter by act, which does not require a mens rea of at least recklessness, criminalizes conduct that goes beyond the contemporary generic definition of manslaughter.
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