William T. Houston v. United States

SILER, Circuit Judge.

William T. Houston was sentenced under 18 U.S.C. § 924(e), the Armed Career Criminal Act (“ACCA”), after his conviction under § 922(g) for being a felon in possession of a firearm. His sentence was enhanced on the basis of three predicate violent felonies under the ACCA: felonious assault, escape, and murder. He appeals the use of his conviction for escape as a predicate violent felony under the ACCA. We affirm.

The sole legal issue is whether Houston’s 1966 conviction for escape can be used as a predicate “violent felony” under 18 U.S.C. § 924(e). That statute provides…