United States v. Brown

EDITH BROWN CLEMENT, Circuit Judge:

Roman A. Brown pleaded guilty and was sentenced under the Armed Career Criminal Act (“ACCA”). On appeal, he claims that the Louisiana crime of simple robbery does not qualify as a “violent felony” for purposes of the ACCA. For the reasons that follow, we affirm the sentence of the district court.

I. FACTS AND PROCEEDINGS

Brown pleaded guilty to possession of a firearm as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). As part of the plea agreement, Brown stipulated that he had been previously convicted of two counts of simple robbery and one count of…