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4th Circuit: SC Involuntary Manslaughter Not a “Violent Felony” Per the ACCA

U.S. v. Jenaro Middleton (No. 16-7556) Jarnaro Carlos Middleton was sentenced as an armed career criminal pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). On appeal, Middleton challenges the district court’s determination that his prior conviction for South Carolina involuntary manslaughter qualifies as a violent felony under the ACCA. Applying the

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Fourth Circuit Reverses District Court; §2255 Petitioner Entitled to Resentencing

United States v. Jolon Carthorne (No. 16-6515) The defendant was convicted of possession of a firearm in furtherance of a drug trafficking crime. At sentencing, the probation officer’s presentence report indicated that defendant was subject to the career offender enhancement, due in part to his prior conviction for Assault and Battery of a Police Officer

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