United States v. Hunt, No. 17-12365 (11th Cir. 2019)
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The Eleventh Circuit vacated its prior opinion and issued the following revised opinion.
The court affirmed defendants' sentences under the Armed Career Criminal Act (ACCA) and USSG 4B1.2(a), holding that defendants' Alabama second-degree and third-degree robbery convictions were predicate offenses under the ACCA where Alabama's statutory scheme utilized the same use-of-force element for all three degrees of robbery. Furthermore, the court's decision in In re Welch, 884 F.3d at 1324, held that force sufficient to overcome the victim's resistance was enough to make an offense a violent felony under the ACCA. The court also held that the district court properly relied on the Sixth Circuit's decision in Chaney v. United States, 917 F.3d 895, 900 (6th Cir. 2019), in holding that the Michigan carjacking conviction was a violent felony under the ACCA, in the absence of any Michigan cases holding that "putting in fear" could be accomplished without force or threatened use of force. Finally, the court held that Defendant Hall's sentence was not substantively unreasonable where the district court did not abuse its discretion in considering the 18 U.S.C. 3553(a) factors.
This opinion or order relates to an opinion or order originally issued on August 14, 2019.
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