United States v. Middleton

The Fourth Circuit reversed the district court's denial of post-conviction relief and remanded for resentencing. The court held that defendant's prior conviction for South Carolina involuntary manslaughter did not qualify as a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). In this case, South Carolina involuntary manslaughter sweeps more broadly than the physical force required under the ACCA's force clause. View "United States v. Middleton" on Justia Law