U.S. v. Haney

Dist. Ct. erred in sentencing defendant to mandatory minimum sentence of 15 years under Armed Career Criminal Act (ACCA) on unlawful possession of firearm charge, where Dist. Ct. improperly found that defendant’s prior Illinois burglary conviction qualified as one of three convictions required for sentencing treatment under said Act. Burglary conviction qualifies for treatment under ACCA if it contains unlawful entry into building with intent to commit crime element, and defendant’s Illinois burglary conviction did not qualify for ACCA treatment because it was broader than generic burglary conviction, since it included unlawful entries into vehicles. Also, remand was required for determination as to whether defendant’s prior Pennsylvania aggravated assault convictions qualified as violent felonies under ACCA.