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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: Assault With Serious Bodily Injury (NC) is a “Crime of Violence” Under U.S.S.G. § 4B1.2

U.S. v. Shawntanna Thompson Shawntanna Lemarus Thompson pled guilty to a drug offense and being a felon in possession of a firearm. The district court increased his sentence, because it found Thompson’s previous state conviction for assault inflicting serious bodily injury constituted a “crime of violence” under § 4B1.2 of the United States Sentencing Guidelines.

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