U.S. v. Waters

Dist. Ct. did not err in sentencing defendant to 188-month term of incarceration on drug conspiracy charge, where said sentence was based, in part, on finding that defendant was eligible for career offender treatment due to prior Illinois enhanced domestic battery conviction, which probation office had characterized as crime of violence. Ct. rejected defendant’s argument that said conviction was not crime of violence because, according to defendant, it did not include use of physical force as element of said offense, after noting that ct. in Holder, 652 F.3d 762, found that domestic battery under Illinois law requires proof of physical force.