U.S. v. Lockett

Dist. Ct. erred in sentencing defendant to 15-year mandatory minimum sentence on unlawful possession of firearm charge, after improperly finding that defendant qualified for treatment under Armed Career Criminal Act (ACCA) based in part on his 1990 state-court drug convictions. While instant 1990 convictions held potential for being predicate convictions under ACCA because they potentially exposed defendant to sentences of 10 or more years, they did not qualify as predicate convictions since: (1) defendant received only 4-year sentences for 1990 convictions; and (2) under Rodriquez, 553 US 377, said convictions could not qualify as predicate convictions for ACCA treatment since state records for said offenses failed to show that defendant actually faced possibility of enhanced sentence of 10 or more years imprisonment.