United States v. Walker

ELLIS, District Judge:

This appeal presents a question of first impression in this circuit, namely the proper Sentencing Guidelines treatment of pri- or convictions for state common law crimes. For the reasons that follow, we hold that the modified categorical approach applicable in this circuit to prior convictions for statutory offenses also applies to prior convictions for state common law crimes. We also conclude that the district court correctly applied this approach in finding that appellant’s prior South Carolina “strong arm robbery” conviction was a crime of violence under U.S.S.G. §…