Dist. Ct. did not err in sentencing defendant to 188-month term of incarceration on firearm and drug charges, where said sentence was premised on finding that defendant qualified for sentencing under Armed Career Criminal Act (ACCA), based, in part, on defendant’s prior Indiana conviction on charge of dealing cocaine. While defendant argued that his Indiana conviction did not qualify as “serious drug offense” for purposes of ACCA, because said offense covered, among other things, financing manufacture of cocaine, which, according to defendant, pertained to conduct outside ACCA’s definition of serious drug offense, Ct. of Appeals found that ACCA’s definition of serious drug offense, which concerned crimes “involving manufacture” of controlled substance, included financing manufacture of cocaine. As such, defendant’s Indiana conviction qualified as serious drug offense for purposes of ACCA.
Federal 7th Circuit Court
Criminal Court
Sentencing