United States Fourth Circuit

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

• Published 2018/02/26

Judges

• GREGORY

Court

• United States Fourth Circuit

Counsel