Background
Dymond Hayden pleaded guilty to being a felon in possession of a firearm in violation of federal law. He challenged his sentence, arguing that his prior conviction for third-degree murder in Minnesota did not qualify as a crime of violence under the Sentencing Guidelines.
The court’s reasoning
The court reviewed the district court’s application of the Guidelines de novo. It determined that Minnesota third-degree murder falls under the enumerated offenses clause of the Sentencing Guidelines definition of a crime of violence. The court adopted the Third Circuit’s definition of generic murder, which includes causing death through conduct evincing reckless and depraved indifference to serious dangers posed to human life. The court found that the Minnesota statute substantially corresponds to this generic definition.
What it means going forward
This decision clarifies that Minnesota third-degree murder convictions will trigger the crime-of-violence enhancement in federal sentencing within the Eighth Circuit.