United States v. Kendrick Maid

772 F.3d 1118, 2014 U.S. App. LEXIS 22135, 2014 WL 6611057
CourtCourt of Appeals for the Eighth Circuit
DecidedNovember 24, 2014
Docket14-1546
StatusPublished
Cited by17 cases

This text of 772 F.3d 1118 (United States v. Kendrick Maid) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Kendrick Maid, 772 F.3d 1118, 2014 U.S. App. LEXIS 22135, 2014 WL 6611057 (8th Cir. 2014).

Opinion

GRUENDER, Circuit Judge.

Kendrick Maid pleaded guilty to possession of a firearm as a felon, a violation of 18 U.S.C. § 922(g). The district court 1 sentenced him to 120 months’ imprisonment. Maid appeals his sentence, arguing that the district court erred in calculating his advisory sentencing guidelines range and that his sentence is unreasonable. We affirm for the reasons explained below.

In April 2013, Maid argued with Tyrone Hurn at Hum’s apartment, then left the residence, promising to return. Shortly thereafter, Maid returned with a gun, pointed it in Hum’s direction, fired two shots at the ceiling, and fled. Maid was indicted for and pleaded guilty to being a felon in possession of a firearm. At sentencing, the district court concluded that Maid’s base offense level was twenty-four, pursuant to USSG § 2K2.1, and determined that his total offense level was twenty-five. This resulted in an advisory sentencing range of 110-137 months’ imprisonment reduced to 110-120 per the statutory maximum, 18 U.S.C. § 924(a)(2). See USSG § 5Gl.l(c). The district court imposed a sentence of 120 months’ imprisonment.

Maid first argues that the district court erred when it determined his base offense level pursuant to USSG § 2K2.1(a)(2). Section 2K2.1(a)(2) provides for a base offense level of twenty-four if the defendant has been convicted of two prior felonies that are crimes of violence as defined in USSG § 4B1.2. Maid concedes that his Iowa conviction for willful injury is a crime of violence but argues that neither his conviction for assault while displaying a dangerous weapon, Iowa Code *1120 §§ 708.1(3) (2002) (current version at Iowa Code § 708.1(2)(c)), 708.2(3), nor his conviction for domestic-abuse assault' with intent to injure or with a weapon, Iowa Code §§ 708.1 (2002) (current version at Iowa Code § 708.1), 708.2A(2)(c), qualifies as a crime of violence. This court reviews de novo a district court’s determination that a conviction is a crime of violence under the sentencing guidelines. United States v. Craig, 630 F.3d 717, 723 (8th Cir.2011).

“To determine whether a prior conviction qualifies as a crime of violence we apply the ‘categorical approach,’ under which ‘we consider the offense generically, that is to say, we examine it in terms of how the law defines the offense and not in terms of how an individual offender might have committed it on a particular occasion.’ ” United States v. Williams, 627 F.3d 324, 327 (8th Cir.2010) (quoting Begay v. United States, 553 U.S. 137, 141, 128 S.Ct. 1581, 170 L.Ed.2d 490 (2008)). Under USSG § 4B1.2(a)(l), a crime of violence includes an offense that “has as an element the use, attempted use, or threatened use of physical force against the person of another.” Maid was convicted of the Iowa crime of assault while displaying a dangerous weapon in violation of Iowa Code §§ 708.1(3) (2002), 708.2(3). A person violates § 708.1(3) (2002) by “[ijntentionally pointing] any firearm toward another, or displaying] in a threatening manner any dangerous weapon toward another.” Section 708.2(3) provides that any person “who commits assault, as defined in section 708.1, and uses or displays a dangerous weapon in connection with the assault, is guilty of an aggravated misdemeanor.” 2 As relevant here, a “dangerous weapon” includes “any instrument or device designed primarily for use in inflicting death or injury” and “any instrument or device ... which is actually used in such a manner as to indicate that the defendant intends to inflict death or serious injury.” Iowa Code § 702.7 (1988) (current version at Iowa Code § 702.7).

Maid argues that his conviction for assault while displaying a dangerous weapon is not a crime of violence because it requires no use or threatened use of physical force. However, both the requirement of “[i]ntentionally pointing] any firearm toward another” and the requirement of “displaying] in a threatening manner any dangerous weapon toward another” under Iowa Code § 708.1(3) (2002) categorically constitute a “threatened use of physical force” under USSG § 4B1.2(a)(l). In United States v. Pulliam, 566 F.3d 784 (8th Cir.2009), we addressed whether a Missouri conviction for unlawful use of a weapon constituted a violent felony under 18 U.S.C. § 924(e)(2)(B)(i). Id. at 787-88. 3 The defendant in Pulliam was convicted of knowingly “exhibiting], in the presence of one or more persons, any weapon readily capable of lethal use in an angry or threatening manner.” Id. at 788 (quoting Mo. Rev.Stat. § 571.030.1(4)). We explained that “[i]t goes without saying that displaying an operational weapon before another in an angry or threatening manner qualifies as a threatened use of physical force” *1121 under § 924(e)(2)(B)®. Id.; see United States v. Forrest, 611 F.3d 908, 910-11 (8th Cir.2010) (finding that crime of felony menacing, which requires knowingly placing or attempting to place another in fear of imminent serious bodily injury by use of a deadly weapon, “easily satis[fies]” the requirement of a threat of physical force under § 924(e)(2)(B)®). Thus, we conclude that Maid’s conviction for assault while displaying a dangerous weapon under Iowa Code §§ 708.1(3) (2002), 708.2(3) categorically qualifies as a crime of violence under USSG § 4B1.2(a)(l). 4 Accordingly, the district court did not err in determining Maid’s base offense level pursuant to § 2K2.1(a)(2).

Maid next argues that his within-guidelines sentence is substantively unreasonable. “[W]e review the substantive reasonableness of [Maid’s] sentence ‘under a deferential abuse-of-discretion standard.’ ” See United States v. Robison,

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Bluebook (online)
772 F.3d 1118, 2014 U.S. App. LEXIS 22135, 2014 WL 6611057, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kendrick-maid-ca8-2014.