UNITED STATES v. WILLIAMS

No. 20-7131.

64 F.4th 149 (2023)

UNITED STATES of America, Plaintiff-Appellee, v. Joseph E. WILLIAMS, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: March 27, 2023.


Attorney(s) appearing for the Case

ARGUED: Geremy C. Kamens, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Richard Daniel Cooke, OFFICE OF THE UNITED STATES ATTORNEY, Richmond, Virginia, for Appellee. ON BRIEF: Frances H. Pratt, Assistant Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Alexandria, Virginia, for Appellant. Jessica D. Aber, United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Richmond, Virginia, for Appellee.

Vacated and remanded by published opinion. Chief Judge Gregory wrote the opinion, in which Judge Harris and Judge Quattlebaum joined.


Joseph Williams was convicted of two firearm possession offenses in violation of 18 U.S.C. § 922(g). In determining Williams's sentence, the trial court applied the Armed Career Criminal Act ("ACCA") sentence enhancement, 18 U.S.C. § 924(e)(1), based on Williams's prior state felony convictions.

Williams now...

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