United States v. Lopez

Court of Appeals for the Ninth Circuit·Decided July 28, 2026·No. 24-3268·Published

Opinion

FOR PUBLICATION

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES OF AMERICA, No. 24-3268 D.C. No.

Plaintiff - Appellee,

1:22-cr-00291-

JLT-SKO-1

v.

JONATHAN LOPEZ, OPINION

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of California Jennifer L. Thurston, District Judge, Presiding

Argued and Submitted May 21, 2026 San Francisco, California

Filed July 28, 2026

Before: Kim McLane Wardlaw, Carlos T. Bea, and Gabriel P. Sanchez, Circuit Judges.

Opinion by Judge Wardlaw

2 USA V. LOPEZ

SUMMARY*

Criminal Law

The panel vacated the sentence imposed on Jonathan Lopez following his guilty plea to possessing a firearm as a prohibited person, in violation of 18 U.S.C. § 922(g)(1), and remanded for resentencing.

The district court enhanced Lopez’s sentence under U.S.S.G. § 2K2.1(a)(2) after determining that he had previously been convicted of two felony “crimes of violence” under California Penal Code § 273.5, a domestic violence offense that punishes a person who “willfully inflicts corporal injury resulting in a traumatic condition.”

Together, Borden v. United States, 593 U.S. 420 (2021), and United States v. Gomez, 165 F.4th 1199 (9th Cir. 2026) (en banc), make clear that to qualify as a categorical crime of violence, an offense requires a mens rea greater than recklessness as to the use of force directed at another person.

The panel held that convictions under § 273.5 do not categorically qualify as crimes of violence, given that § 273.5—a general intent crime—requires only the mens rea of intending to do the assaultive act and does not require intent, or knowledge, that the use of force is directed at another. This court’s previous cases, which held that § 273.5 is a categorical crime of violence without determining whether § 273.5 requires a mens rea greater

*

This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.

USA V. LOPEZ 3

than recklessness as to the use of force directed at another, must be overruled as clearly irreconcilable with Borden and Gomez. Accordingly, the district court, while properly applying prior precedent, should not have applied § 2K2.1(a)(2) to enhance Lopez’s sentence.

COUNSEL

Cody Chapple (argued) and Arin C. Heinz, Assistant United States Attorneys; Nirav K. Desai, Assistant United States Attorney, Appellate Chief, Criminal Division; Phillip A. Talbert, United States Attorney; Office of the United States Attorney, United States Department of Justice, Fresno, California; for Plaintiff-Appellee. Peggy Sasso (argued), First Assistant Federal Defender; Christina Corcoran, Assistant Federal Public Defender; Heather E. Williams, Federal Defender; Office of the Federal Defender, Fresno, California; for Defendant- Appellant.

4 USA V. LOPEZ

OPINION

WARDLAW, Circuit Judge:

Jonathan Lopez pleaded guilty to possessing a firearm as a prohibited person in violation of 18 U.S.C. § 922(g)(1). The district court enhanced his sentence, under U.S.S.G § 2K2.1(a)(2), after determining that Lopez had previously been convicted of two felony “crimes of violence,” under California Penal Code § 273.5,1 a domestic violence offense that punishes a person who “willfully inflicts corporal injury resulting in a traumatic condition.”

Lopez appeals his sentence, arguing that a conviction under Cal. Penal Code § 273.5 is not a categorical crime of violence. We have previously held that § 273.5 is a categorical crime of violence, but these decisions are clearly irreconcilable with the Supreme Court’s ruling in Borden v. United States, 593 U.S. 420 (2021), and our recent en banc decision in United States v. Gomez, 165 F.4th 1199 (9th Cir. 2026) (en banc), cert. denied, No. 25-7193, 2026 WL 1377030 (U.S. May 18, 2026). Together, Borden and Gomez make clear that to qualify as a categorical crime of violence an offense requires a mens rea greater than recklessness as to the use of force directed at another person. Thus, in light of Borden and Gomez, we hold that convictions under Cal.

1 Cal. Penal Code § 273.5 is a “wobbler” offense in California, meaning that it can be “chargeable or . . . punishable as either a felony or a misdemeanor.” People v. Valencia, 3 Cal. 5th 347, 351 n.2 (2017) (quoting People v. Park, 56 Cal. 4th 782, 789 (2013)); see also Cal. Penal Code § 273.5(a) (explaining that the authorized punishment is either a term in state prison “or in a county jail for not more than one year”). Here, both parties agree that Lopez’s two previous § 273.5 convictions were punished as felonies.

USA V. LOPEZ 5

Penal Code § 273.5 do not categorically qualify as crimes of violence. Our prior precedent holding that § 273.5 is categorically a crime of violence must be overruled under Miller v. Gammie, 335 F.3d 889, 893 (9th Cir. 2003) (en banc), because it is clearly irreconcilable with the Supreme Court’s opinion in Borden, and our en banc decision in Gomez. Thus, we hold that the district court incorrectly applied the sentencing enhancement for two felony crimes of violence in this case.

I.

On November 3, 2022, Lopez was charged by indictment with a single count of possessing a firearm as a prohibited person in violation of 18 U.S.C. § 922(g)(1). Lopez pleaded guilty pursuant to a plea agreement that preserved Lopez’s right to appeal “a finding by the District Court that the defendant’s prior convictions” under Cal. Penal Code § 273.5 “are crimes of violence under U.S.S.G. § 2K2.1(a)(2).”

Before sentencing, the probation office prepared a presentence report that determined that Lopez “ha[d] two felony convictions for offenses considered to be crimes of violence,” because he had two previous convictions for violations of Cal. Penal Code § 273.5. Probation therefore concluded that Lopez’s base offense level was 24, due to the application of U.S.S.G. § 2K2.1(a)(2), which applies when the defendant unlawfully possesses a firearm “subsequent to sustaining at least two felony convictions of [] a crime of violence.” Without the “crime of violence” enhancement, Lopez’s base offense level would have been 14. See U.S.S.G. § 2K2.1(a)(6). The probation office recommended a three-level reduction for acceptance of responsibility and assistance to authorities, resulting in a total offense level of 6 USA V. LOPEZ

21 and a recommended Sentencing Guidelines range of 77 to 96 months. Both the probation office and the government recommended a sentence of 77 months.

At the sentencing hearing, Lopez objected to the probation office’s determination that a conviction under Cal. Penal Code § 273.5 qualifies as a crime of violence. The district court overruled the objection “[b]ecause of the binding Ninth Circuit authority,” and therefore agreed with the probation office that the applicable offense level was 21 and that the Sentencing Guidelines range was 77 to 96 months. The district court varied downward slightly and sentenced Lopez to a custody term of 67 months.

II.

U.S.S.G. § 2K2.1(a)(2) increases the base offense level for certain firearms offenses when the defendant has at least two previous felony convictions for crimes of violence. For purposes of this enhancement, a crime of violence is defined, in part, as “any offense under federal or state law, punishable by imprisonment for a term exceeding one year, that . . . has as an element the use, attempted use, or threatened use of physical force against the person of another.” U.S.S.G. § 4B1.2(a). We have referred to this portion of the definition as the “elements clause.” See, e.g., United States v. Davis, 588 U.S. 445, 449 (2019); Gomez, 165 F.4th at 1203; see also Borden, 593 U.S. at 424 (plurality opinion) (describing the “elements clause”).

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Related

§ 922
18 U.S.C. § 922
§ 924
18 U.S.C. § 924
§ 16
18 U.S.C. § 16