United States v. Osman Reyes

866 F.3d 316, 2017 WL 3262281, 2017 U.S. App. LEXIS 14068
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 1, 2017
Docket16-40241
StatusPublished
Cited by49 cases

This text of 866 F.3d 316 (United States v. Osman Reyes) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth 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. Osman Reyes, 866 F.3d 316, 2017 WL 3262281, 2017 U.S. App. LEXIS 14068 (5th Cir. 2017).

Opinions

REAVLEY, Circuit Judge:

This Court implicitly held in United States v. Velasco, 465 F.3d 633 (5th Cir. 2006), that the Illinois aggravated battery statute is divisible—meaning that if a defendant has a prior conviction under that statute and a sentencing court must determine whether this prior conviction qualifies for a sentencing enhancement, the court should look to certain records of conviction to identify the particular offense of which the defendant had been convicted. Applying Mathis v. United States, — U.S. —, 136 S.Ct. 2243, 195 L.Ed.2d 604 (2016), we must decide whether that holding retains vitality. We find that it does.

Recitation of only a few facts is necessary. In April of 2015, defendant Osman Rutilio Reyes was convicted of aggravated battery under Illinois’ aggravated battery statute, 720 Ill. Comp, Stat. Ann. § 5/12-3.05. More specifically, he was convicted of aggravated.battery with a deadly weapon under Section 5/12-3.05(f)(l). Reyes was deported in May of that year. By August, he was back in the country. Immigration and Customs Enforcement agents apprehended him in Texas, and he pleaded guilty to violating 8 U.S.C. § 1326.

The district court found that Reyes’ pri- or conviction qualified as a crime of violence for. purposes of the United States Sentencing Guidelines and imposed a 16-level sentencing enhancement when calcu[318]*318lating the applicable Guidelines range. See USSG § 2L1.2(b)(l)(A)(ii). This ruling was required by Velasco, which had held that a conviction under the Illinois aggravated battery statute for aggravated battery based on the use of a deadly weapon necessarily involved “the use of force” and therefore categorically qualified as a crime of violence. 465 F.3d at 638-40 (citing 720 Ill. Comp. Stat. 5/12-4(b)(l)). The opinion also recognized that when Illinois’ aggravated battery statute cannot be “pare[d] down,” a conviction under the statute will not categorically qualify as a crime of violence because the “statute provides for the commission of the offense of aggravated battery in a number of different ways, some of which do =Hot require the use of physical force against a person.” Id. at 639 (quoting United States v. Aguilar-Delgado, 120 Fed.Appx. 522, 523 (5th Cir. 2004)).

Though Velasco foreclosed his argument, Reyes duly objected to a crime-of-violence sentencing enhancement on the grounds that the Illinois aggravated battery statute is indivisible. As that very case shows, a finding of indivisibility would establish the sentencing enhancement’s impropriety. See Velasco, 465 F.3d at 639. Oh appeal, we consider Reyes’ divisibility argument in light of Mathis, and review is de novo. See United States v. Sam, 467 F.3d 857, 861 (5th Cir. 2006). Because Reyes is challenging a precedent of this Court, he must show that Mathis “unequivocally abrogated” Velasco. United States v. Tanksley, 848 F.3d 347, 350 (5th Cir.), supplemented, 854 F.3d 284 (5th Cir. 2017). Mathis “is controlling regarding the methodology of the modified categorical approach,” United States v. Hinkle, 832 F.3d 569, 574 (5th Cir. 2016), so our task is to check the result of Velasco according to the method of Mathis, see Tanksley, 848 F.3d at 351.

The broad issue in this case is whether Reyes’ conviction under the Illinois aggravated battery statute properly counts as a crime of violence under the Guidelines. “To determine whether a given prior conviction qualifies for a Guidelines enhancement, courts use either (1) the categorical approach or (2) the modified categorical approach.” United States v. Rico-Mejia, 859 F.3d 318, 322 (5th Cir. 2017). Courts applying the categorical approach simply “look to the elements of the offense enumerated or defined by the Guideline section and compare those elements to the elements of the prior offense for which the defendant was convicted.” United States v. Howell, 838 F.3d 489, 494 (5th Cir. 2016).

Some statutes resist this approach because they “list elements in the alternative, and thereby define multiple crimes.” Mathis, 136 S.Ct. at 2249. When confronted with such a statute, courts employ the modified categorical approach and examine “a limited class of documents (for example, the indictment, jury instructions, or plea agreement and colloquy) to determine what crime, with what elements, a defendant was convicted of.” Id. Some statutes seem at a glance to bear this same structure but, upon examination, merely list “various factual means of committing a single element.” Id. When a statute lists different possible ways of committing one crime, the modified categorical approach is impermissible. Id. at 2251.

The Illinois aggravated battery statute is lengthy and complex. See 720 Ill, Comp. Stat. § 5/12-3.05(a)-(g). According to the government, the statute sets forth the necessary alternative elements that render the modified categorical approach permissible and allow Reyes’ prior conviction to be identified as an aggravated battery involving the use of a deadly weapon. See 720 Ill. Comp. Stat. § 5/12-3.05(f)(l). According to Reyes, the statute is indivisible [319]*319and “overbroad” in that it “sweeps in conduct that does not qualify as a ‘crime of violence.’ ” Reyes’ fallback position is that even if the aggravated battery statute can be narrowed to Section 5/12-3.Q5(f), it' cannot be narrowed further. In other words, Section 5/12-3.05(f) is itself indivisible and overbroad.

In determining if the aggravated battery statute is divisible, we look to its alternative components and ask “elements or means?” Mathis, 136 S.Ct. at 2256. State law governs this “threshold inquiry.” Id. State courts are the ideal expositors of state law, but we may also examine the statutory text and structure or, if necessary, “the record of a prior conviction itself.” Id. If the Illinois aggravated battery statute lists various means of committing one aggravated battery offense, it is indivisible. Hinkle, 832 F.3d at 575. In such a case, a jury need not agree on how the offense was committed, and Reyes’ crime of conviction could not be narrowed to encompass any one factual theory, no matter the actual evidence or indictment in his case. Mathis, 136 S.Ct. at-2251. Elements, by contrast, are those “things the ‘prosecution must prove to sustain a conviction.’ ” Id. at 2248 (quoting. Black’s Law Dictionary 634 (10th ed. 2014)). Distilled to its essence, Mathis recognizes that, when applying a recidivism statute to a defendant’s prior convictions, each “crime of conviction” is defined by solely by its elements. Id. at 2251. “How a given defendant actually perpetrated the crime” is irrelevant, “regardless of whether a statute omits or instead specifies alternative possible means of commission.” Id.

We first consider Reyes’ broad argument: that the “aggravated battery statute contains [a] lengthy list of ways that a person can violate the statute.” (Emphasis added-(citing 720 Ill. Comp. Stat. § 5/12-3.05(a)-(g)).) Do its many subsections and their nested paragraphs simply establish a multiplicity of ways of committing one aggravated battery offense? No.

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Cite This Page — Counsel Stack

Bluebook (online)
866 F.3d 316, 2017 WL 3262281, 2017 U.S. App. LEXIS 14068, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-osman-reyes-ca5-2017.