UNITED STATES OF AMERICA v. VINSON THOMPSON
The Fourth Circuit affirmed Vinson Thompson's Armed Career Criminal Act sentence because his challenge regarding the lack of a jury finding was procedurally barred by the plain error standard. The court concluded that while the district court erred by not advising Thompson of his right to a jury on the 'different occasions' element, the error did not affect his substantial rights given the overwhelming evidence of his criminal history.