United States v. Love, No. 20-2297 (7th Cir. 2021)
Annotate this CaseLove sold crack to a confidential informant. Officers searched his apartment and found crack in the kitchen and found two guns and ammunition in an adjoining room, about 15 feet from the drugs. Love pleaded guilty to three drug counts and one felon-in-possession count (18 U.S.C. 922(g)(1)). A violation of section 922(g)(1) causes a default sentencing range of up to 10 years but the Armed Career Criminal Act increases the penalty to a 15-year mandatory minimum if the defendant had three previous convictions for violent felonies or serious drug offenses, 18 U.S.C. 924(e)(1). Love’s prior convictions included Illinois armed robbery (1994), federal distribution of crack cocaine (2009), and Indiana Class D battery resulting in bodily injury (2015). Love argued that he received a “restoration of rights” letter without an express reference to guns after he was released on the 1994 Illinois armed robbery conviction and that his Indiana Class D battery-resulting-in-bodily-injury conviction was not a crime of violence. The judge held the armed robbery conviction was an ACCA predicate but that the battery-resulting-in-bodily-injury conviction was not, as a categorical matter, a “violent felony,” so Love was not an armed career criminal. The judge sentenced Love to 96 months’ imprisonment. The Seventh Circuit reversed. Love committed three ACCA-predicate offenses.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.