United States v. Counts

In this appeal, Richard Counts challenges the district court’s 1 imposition of a sentence of 180 months’ imprisonment for possession of a firearm as a previously-convicted felon, in violation of 18 U.S.C. § 922(g)(1). Counts disputes the district court’s determination that his prior Missouri conviction for first-degree tampering with an automobile is a “violent felony” within the meaning of 18 U.S.C. § 924(e)(1). Upon de novo review, and in light of governing circuit precedent, we affirm.

Section 924(e) provides that a defendant convicted under § 922(g)(1) is subject to a mandatory term of…