U.S. v. Sims

Dist. Ct. did not err in sentencing defendant to 180-month term of incarceration on unlawful possession of firearm charge after finding that defendant qualified for 15-year mandatory minimum sentence under Armed Career Criminal Act (ACCA) due to existence of two prior convictions on unlawful drug delivery charge, as well as unlawful drug possession with intent to deliver charge that occurred one week apart. Ct. rejected defendant’s claim that both prior convictions should have been treated as single criminal episode, after Ct. found that two drug sales, even occurring sequentially, can be distinct offenses under ACCA, and that due to instant one-week separation, defendant failed to otherwise meet burden of showing that his prior drug offenses formed part of single criminal occurrence for purposes of ACCA.