United States v. Trinkle

ORDER DENYING CERTIFICATE OF APPEALABILITY

HARRIS L. HARTZ, Circuit Judge.

Defendant Billy Trinkle filed a motion for relief under 28 U.S.C. § 2255 in the United States District Court for the District of Kansas, claiming that his two prior convictions for criminal threat did not constitute convictions of “crimes of violence” under the career-offender sentencing enhancement of the United States Sentencing Guidelines, § 4B1.1. The court denied the motion but granted his request for a certificate of appealability (COA) on one ground for his claims. See 28 U.S.C. § 2253(c)(1)(B) (requiring COA to…