United States v. Park

OPINION

WALLACE, Senior Circuit Judge:

In August 2009, Park pleaded guilty to being a felon in possession of a firearm, which is prohibited by 18 U.S.C. § 922(g)(1). The government now appeals from Park’s 37-month sentence, arguing that the district court erred when it refused to impose a “crime of violence” sentencing enhancement based on Park’s pri- or conviction for first-degree burglary in California. According to the government, the district court should have applied the enhancement because California first-degree burglary is categorically a “crime of violence” under section 2K2.1(a) of…