United States v. Dixon

The Eleventh Circuit affirmed defendant's sentence at the bottom of the guideline range after he pleaded guilty to being a felon in possession of a firearm and ammunition. The court held that Florida's domestic-battery-by-strangulation statute qualifies as a "crime of violence" under the elements clause because it requires conduct that categorically requires the use of violent force. Therefore, the district court did not err by sentencing defendant as an armed career criminal based in part by his prior Florida conviction for domestic battery by strangulation. View "United States v. Dixon" on Justia Law