United States v. Lazaro Lobaton-Andrade

Defendant-Appellant Lazaro Lobaton-Andrade pleaded guilty to illegal reentry after deportation and was sentenced to 46 months of imprisonment. Lobaton-An-drade appeals his sentence, asserting that a 2007 Arkansas manslaughter conviction does not qualify as “manslaughter,” an enumerated “crime of violence” offense under United States Sentencing Guidelines § 2L1.2. Thus, Lobaton-Andrade contends, the district court erred in applying a 16-level crime of violence sentencing enhancement based on that conviction. We agree, and we VACATE his sentence and REMAND to the district court for…