United States v. Reid

The Fourth Circuit affirmed defendant's sentence of 15 years in prison under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1). The court applied the categorical approach and held that defendant's three prior convictions under Virginia Code 8.2-55, for inflicting bodily injury, qualified as a violent felony because a defendant must necessarily use force capable of causing physical pain or injury. View "United States v. Reid" on Justia Law