United States v. Williams

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Trayon Williams was convicted of possessing a firearm after a felony conviction. To apply the federal sentencing guidelines, the district court classified Williams’s prior conviction for aggravated battery under Kansas law as a crime of violence. This classification triggered enhancement of the offense level. U.S. Sentencing Guidelines Manual section 2K2.1(a)(4)(A). Williams challenged the enhancement on the ground that his prior conviction was not for a crime of violence. The Tenth Circuit found Williams was mistaken: in Kansas, aggravated battery was a crime of violence because the crime involves general criminal intent, requiring the knowing use of force. View "United States v. Williams" on Justia Law