United States v. Sellers

Defendant was convicted of unlawfully possessing a firearm and was sentenced as an armed career criminal under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), based on his prior South Carolina drug convictions. The court affirmed its holding in United States v. Williams, directing that courts evaluating whether a prior conviction qualifies as a predicate for a federal sentence enhancement look to the statutory penalty for the prior conviction. In Williams, Youthful Offender Act (YOA), S.C. Code Ann. 24-19-50, offenses can qualify as ACCA predicates because the maximum statutory penalty for the prior conviction is unaffected by the state court’s exercise of its discretion to impose a sentence of six years or less in custody. Accordingly, the court affirmed the judgment. View "United States v. Sellers" on Justia Law