Currently Browsing:ACCA

4th Circuit: SC Involuntary Manslaughter Not a “Violent Felony” Per the ACCA

U.S. v. Jenaro Middleton (No. 16-7556) Jarnaro Carlos Middleton was sentenced as an armed career criminal pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). On appeal, Middleton challenges the district court’s determination that his prior conviction for South Carolina involuntary manslaughter qualifies as a violent felony under the ACCA. Applying the

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Fourth Circuit: NC Voluntary Manslaughter is a Violent Felony Per the ACCA

United States v. Antoine Darrell Smith (No. 17-4015) Smith pled guilty to one count of PWID cocaine, and one count of possession of ammunition by a convicted felon. Smith’s PSI indicated that he was subject to enhanced penalties under the ACCA, due in part to his North Carolina conviction for voluntary manslaughter. Smith argued that

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