Dist. Ct. did not err in sentencing defendant to 105-month term of incarceration on felon in possession of firearm charge, where said sentence was based, in part, on finding that defendant had at least two prior felony convictions for "crimes of violence" under section 2K2.1(a)(2) of USSG. Defendant conceded that his California conviction for assault with deadly weapon qualified as crime of violence, and his Iowa conviction for aggravated assault qualified as "crime of violence" under categorical approach because it contained as element threatened use of physical force. Ct. rejected defendant's claim that mere displaying of weapon at issue in Iowa conviction did not necessarily imply or indicate its use, and defendant otherwise produced no case in which defendant was convicted for aggravated assault while accidentally displaying weapon.
