U.S. v. Doss

Defendant pleaded guilty to being a felon in possession of a firearm. During sentencing, the district court enhanced the base offense level because defendant previously was convicted of sexual battery. On appeal, defendant argued that the district court erred in applying the “crime of violence” enhancement based on his prior sexual battery conviction. The Seventh Circuit affirmed, finding that defendant’s prior offense was a forcible sex offense that constituted a crime of violence for the purposes of sentencing. (RIPPLE and HAMILTON, concurring)