Jerry Brown v. United States
Court of Appeals for the Eighth Circuit
1Opinion of the Court
STRAS, Circuit Judge.
The question in this case is whether Jerry Brown's 1977 Missouri conviction of second-degree burglary is a "violent felony" under the Armed Career Criminal Act. Because we conclude that it is not, we remand for resentencing.
I
In 2007, Brown pleaded guilty to being a felon in possession of a firearm. The district court imposed a 15-year statutory-minimum sentence under the Armed Career Criminal Act ("ACCA") because he had three previous convictions for "violent felon[ies]." 18 U.S.C. § 924(e)(1). One of them was a 1977 conviction under Missouri's since-repealed…
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