United States v. Yang, No. 14-3688 (7th Cir. 2015)
Annotate this CaseYang pled guilty to being a felon in possession of a firearm, 18 U.S.C. 922(g)(1). The district court found that Yang had three felony convictions that could be classified as violent under the Armed Career Criminal Act and imposed the resulting mandatory minimum sentence of 15 years in prison, 18 U.S.C. 924(e)(1). The Seventh Circuit affirmed, rejecting an argument that the state court document recording one of the convictions did not clearly identify the statute of conviction and that the district court was not permitted to look beyond the face of the document to identify the statute of conviction to impose the heavier ACCA sentence. The conviction in question was for felony domestic assault under Minnesota Statute 609.224(4), which is a violent felony under ACCA. The district court could consult the relevant sentencing and plea transcripts to identify the statute of conviction without running afoul of ACCA or the Supreme Court’s decisions interpreting it.
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