United States v. Ashford Spencer

OPINION

BYBEE, Circuit Judge:

Ashford Kaipo Spencer was convicted of two federal drug-trafficking felonies. At sentencing, the district court determined that Spencer was a “career offender” under § 4B1.1 of the Sentencing Guidelines because Spencer had two prior convictions for “crimes of violence,” as defined in § 4B1.2(a), In making this determination, the district court applied the “categorical approach” to conclude that Spencer’s prior conviction for criminal property damage in the first degree under § 708-820(l)(a) of the Hawaii Revised Statutes constituted a conviction for a “crime of…