Light v. Caraway

Dist. Ct. did not err in denying defendant’s section 2241 petition challenging his 235-month sentence on unlawful possession of firearm charge, where said sentence was based in part on finding that defendant qualified as armed career criminal due to three of his prior convictions that included conviction for criminal vehicular operation that resulted in substantial bodily harm. While under Begay, said conviction no longer qualified as violent crime for purposes of Armed Career Criminal Act (ACCA), one of defendant’s additional convictions, i.e., fleeing police officer in vehicle, which had not been considered as violent crime at time of his sentencing, was now considered violent crime so as to establish defendant’s eligibility for treatment under ACCA. Ct. rejected defendant’s claim that case law that rendered fleeing officer in vehicle as qualifying offense under ACCA could not be retroactively applied to him.