Russell Abrutyn

Abrutyn Law PLLC

3765 12 Mile Road

Berkley, MI 48072


Friday, April 16, 2010

Federal Escape Conviction not Categorically a Crime of Violence

USA v. Anglin, http://www.ca6.uscourts.gov/opinions.pdf/10a0098p-06.pdf (published).

The Court employed the categorical approach and looked at the limited record of conviction to determine if defendant's federal escape conviction is a crime of violence for career offender sentencing purposes.  To be a crime of violence, that is whether it poses a serious potential risk of violence, it must involve purposeful, violent, and aggressive conduct.

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