U.S. v. Brown

Dist. Ct. did not err in sentencing defendant to 180-month term of incarceration on bank robbery charge, where said sentence was based, in part, on finding that defendant qualified for enhanced career-offender treatment under section 4B1.1 of USSG based in part on defendant’s pre-2013 Illinois conviction on aggravated vehicular hijacking charge. Ct. of Appeals found that said conviction qualified as “crime of violence” for purposes of career-offender enhancement. Ct. rejected defendant’s argument that mental state of recklessness could be implied as element of said offense, where statute did not expressly prescribe any mental state.