Legal Opinion
United States v. Jarnaro Middleton
Court of Appeals for the Fourth Circuit
Decided February 26, 2018No. 16-7556PublishedCited by 51 opinions
1Opinion of the Court
GREGORY, Chief Judge:
*487 Jarnaro Carlos Middleton was sentenced as an armed career criminal pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924 (e). Middleton challenges the district court's determination that his prior conviction for South Carolina involuntary manslaughter qualifies as a violent felony under the ACCA. Due to the idiosyncrasies of the Supreme Court's "categorical approach," the ultimate issue in this case is whether selling alcohol to a minor involves the requisite use of violent force. We conclude that it does not and reverse.
I
On December 29, 2005, Middleton pled…
2Cases cited46 opinions
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- Johnson v. United StatesSupreme Court of the United States · 2015
- Alexander v. SandovalSupreme Court of the United States · 2001
- Descamps v. United StatesSupreme Court of the United States · 2013
- Johnson v. United StatesSupreme Court of the United States · 2010
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3Cited by51 opinions
- United States v. Garnett HodgeCourt of Appeals for the Fourth Circuit · 2018
- Therl Taylor v. Virginia GrubbsCourt of Appeals for the Fourth Circuit · 2019
- United States v. David RunyonCourt of Appeals for the Fourth Circuit · 2020
- Lassend v. United StatesCourt of Appeals for the First Circuit · 2018
- United States v. Kevin BattleCourt of Appeals for the Fourth Circuit · 2019
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