United States v. Sayles

MELLOY, Circuit Judge.

Louis Sayles pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). At sentencing, the district court applied United States Sentencing Guidelines § 2K2.1(a)(4)(A) to determine a base offense level and found a prior conviction for manslaughter qualified as a “crime of violence.” Sayles challenged this determination, arguing that the mens rea for the earlier manslaughter conviction was recklessness and that the offense did not qualify as a crime of violence. The district court rejected Sayles’s challenge and found…