United States Fourth Circuit

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US v. Middleton, 167556

Reversing a district court's determination that a prior conviction for South Carolina involuntary manslaughter qualifies as a violent felony under the Armed Career Criminal Act because in a quirk of the Supreme Court's categorical approach the ultimate issue swung on whether selling alcohol to a minor involved the use of violent force, which it does not.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2018/02/26




  • United States Fourth Circuit


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