United States v. Eric Scanlan

Eric S. Scanlan pleaded guilty to possession of a firearm by a felon. See 18 U.S.C. § 922(g)(1). The district court set a base offense level of 24, see U.S.S.G. § 2K2.1(a)(2), relying in part on a California burglary conviction that the district court considered a crime of violence. Scanlan argues that the district court committed plain error by treating the burglary conviction as a crime of violence. We affirm the sentence.

Police in Milwaukee, Wisconsin, arrested Scanlan after receiving a tip that he would be arriving in town by bus from California wearing a bulletproof vest and carrying…