Background
The defendant pleaded guilty to possession of a firearm by a convicted felon. The district court determined he had three prior violent felonies, triggering an enhanced sentence under the Armed Career Criminal Act. The case was remanded once to reconsider the different occasions inquiry following a Supreme Court decision, and on resentencing, the defendant received an 184-month sentence. He appealed, challenging the constitutionality of the statute and the application of the enhancement.
The court’s reasoning
The court held that Second Amendment challenges to the statute are barred by binding circuit precedent. Regarding the Armed Career Criminal Act, the court found that the prior convictions qualified as violent felonies under existing law. The court addressed a potential error where the judge, rather than a jury, determined the predicate offenses occurred on different occasions. Applying harmless error review, the court concluded the error was harmless because the defendant pleaded guilty with full knowledge of the sentencing range, did not dispute the factual basis in the presentence report, and the evidence of separate occasions was overwhelming.
What it means going forward
The decision reinforces the binding nature of Fourth Circuit precedent on Second Amendment challenges for felons and clarifies that procedural errors in determining different occasions for sentencing enhancements are often harmless when a defendant has entered a knowing and voluntary guilty plea.
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