United States v. Quantrell Reid

NIEMEYER, Circuit Judge:

After Quantrell Reid pleaded guilty to possession of a firearm by a felon, in violation of 18 U.S.C. § 922(g)(1), the district court sentenced him to 15 years’ imprisonment under the Armed Career Criminal Act (“ACCA”) because he had three previous convictions for a “violent felony,” id. § 924(e)(1). Specifically, the court found that Reid’s three prior convictions under Virginia Code § 18.2-55, which has as an element the knowing and willful infliction of bodily injury, fell within ACCA’s definition of “violent felony” because the state crime “has as an element the use…