U.S. v. Anderson

Court of appeals considered the question of whether the district court improperly enhanced defendant’s sentence under the Armed Career Criminal Act, which mandates a 15-year minimum sentence for individuals convicted of possessing a firearm after three or more prior convictions for a “violent felony.” Defendant argued on appeal that one of the prior convictions relied on by the district court was not a violent felony. The appellate court agreed, vacated defendant’s sentence and remanded for re-sentencing, finding that the prior conviction was not a predicate violent felony because it encompassed reckless conduct. (WOOD, concurring and RIPPLE, dissenting)