United States v. Trent

*1048HARTZ, Circuit Judge.

Defendant Richard Trent appeals his conviction and sentence for being a felon in possession of a firearm. He raises five issues that can be disposed of briefly and a challenging issue about whether we can apply what is called the “modified categorical approach” to determine whether his prior felony is a “serious drug offense” under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). On the ACCA issue we hold that the general Oklahoma conspiracy statute is divisible and therefore subject to the modified categorical approach, and that Defendant’s prior violation of…