United States v. James Howard

COLLOTON, Circuit Judge.

James Howard pleaded guilty to unlawful possession of a firearm as a previously convicted felon, in violation of 18 U.S.C. § 922(g). Based on Howard’s criminal history, the district court 1 sentenced Howard to the statutory minimum sentence of fifteen years’ imprisonment under the Armed Career Criminal Act (“ACCA”). See 18 U.S.C. § 924(e). Howard appeals, arguing that neither of his sexual-abuse convictions qualifies as a violent felony under the ACCA, and that the Act’s residual clause is unconstitutionally vague. We affirm.

Under the ACCA, a defendant convicted…