United States v. Carl Miller

TINDER, Circuit Judge.

When Carl T. Miller pleaded guilty to being a felon in possession of a firearm in 2011, the government contended that three of his prior convictions qualified as “violent felonies” requiring a mandatory minimum 15-year sentence under the Armed Career Criminal Act (ACCA). See 18 U.S.C. § 924(e)(1). Miller did not dispute that his two burglary convictions qualified as violent felonies but he objected to the third prior offense — possession of a short-barreled shotgun in violation of Wisconsin law. The objection required the district court to construe the meaning of ACCA’s…