United States v. John Foster

The Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), imposes a 15-year minimum sentence on defendants convicted of illegally possessing a firearm, see id. § 922(g)(1), who also have at least three prior convictions for a “violent felony” or a “serious drug offense.” Id. § 924(e)(1). After John Foster pleaded guilty to illegal gun possession under § 922(g)(1), the district court considered him to have three such qualifying convictions and sentenced him to 15 years in prison. Foster does not contest that two of his prior convictions qualify under ACCA. Those convictions were for dealing in…