United States v. Kenneth Jefferson

Kenneth David Jefferson appeals his 188-month sentence, arguing that the district court 2 plainly erred in classifying him as an armed career criminal. We affirm.

I. Background

Jefferson pleaded guilty to one count of being a felon in possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). Prior to sentencing, the presen-tence investigation report (PSR) revealed that Jefferson “has at least three prior convictions for a violent felony or serious drug offense, or both,” including felony drug-trafficking convictions in 2001, 2004, and 2008 from Illinois. Based on these…