US v. Lawrence, No. 09-30285

Felon In Possession Sentence Affirmed

In US v. Lawrence, No. 09-30285, the court affirmed defendant's sentence for being a felon in possession of a firearm and ammunition where a violation of Wash. Rev. Code section 9A.36.02 (1)(a) qualified as a violent felony under the categorical approach because it "had as an element the use, attempted use, or threatened use of physical force against the person of another."

As the court wrote:  "Anthony L. Lawrence was convicted by a jury of being a felon in possession of a firearm and ammunition in violation of 18 U.S.C. § 922(g)(1), following his involvement in a shooting in early 2008. At sentencing, the district court determined that the Armed Career Criminal Act's ("ACCA") fifteen-year mandatory minimum sentence applied in Lawrence's case. Lawrence now appeals his sentence, arguing that the government failed to prove that he had three previous qualifying convictions that would trigger the ACCA's mandatory minimum."

Related Resources

• Read the Ninth Circuit's Decision in US v. Lawrence, No. 09-30285