U.S. v. Fife

Dist. Ct. erred in sentencing defendant to 48-month term of incarceration on firearms charge, after improperly rejecting govt. argument that defendant should have been sentenced to minimum term of 15 years as armed career offender. Defendant had previously been sentenced as armed career offender based in part on Ill. armed violence conviction, and said conviction still qualified as violent offense where said offence involved defendant's possession of cocaine with intent to deliver while armed with weapon since said offense involved serious potential risk of physical injury.