United States Eighth Circuit

Defendant's firearm possession sentence is vacated where the court of appeals was unable to resolve, without conjecture, whether defendant's prior adjudication of juvenile delinquency qualified as a conviction for a violent felony under the Armed Career Criminal Act, because the court could not determine in the first instance whether defendant's juvenile adjudication involved possessing a sawed-off rifle as opposed to possessing some "other implement," such as a knife.

Appellate Information

• Decided 03/26/2010
• Published 03/26/2010

Judges

Court

• United States Eighth Circuit

Counsel