United States v. Thilo Brown

DUNCAN, Circuit Judge:

Petitioner-Appellant Thilo Brown appeals the district court’s order dismissing his 28 U.S.C. § 2255 motion. This court granted Petitioner a certificate of appeala-bility on the issue of whether, in light of Johnson v. United States, — U.S. -, 135 S.Ct. 2551, 192 L.Ed.2d 569 (2015), his prior South Carolina conviction for assault on a police officer while resisting arrest, S.C. Code Ann. § 16-9-320(B) (“Resisting-Arrest Assault Conviction”), qualifies as a *299predicate “crime of violence” for career-offender status under the Sentencing Guidelines, U.S.S.G. §§ 4Bl.l(a),…