U.S. v. Carr

Defendant appealed from his sentence after being found guilty of being a felon in possession of a firearm, arguing that it was error for the district court to increase his offense level and sentencing range because of three prior state court convictions for armed robbery, which the district court treated as crimes of violence. The Seventh Circuit rejected defendant’s argument that his prior convictions for armed robberies could not be considered as predicates for an enhanced offense level and affirmed that aspect of the sentence; however, the Seventh Circuit vacated and remanded for the limited purposes of instructing the district court to reconsider defendant’s request for sentencing reduction to account for the time he initially spent in county detention on state charges and while serving the remainer of his revoked parole on the prior charges. (EASTERBROOK and ST. EVE, concurring)