United States v. Santiago

ANDERSON, Circuit Judge:

This case presents the question of whether a guilty plea followed by a sentence of probation and a withholding of adjudication qualifies under Florida law as a predicate conviction for the purpose of enhancing a defendant’s sentence under the Armed Career Criminal Act (“ACCA”), 18 U.S.C. § 924(e). Defendant Euladio Santiago, Jr. pleaded guilty to possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). The government argued that Santiago had three prior felony convictions, mandating an enhanced sentence under the ACCA. At sentencing, the…