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Criminal Practice – SC involuntary manslaughter can be non-violent (access required)

Holding: The defendant’s prior conviction for involuntary manslaughter in South Carolina did not qualify as a “violent felony” under the Armed Career Criminal Act. Background Appellant Jarnaro Carlos Middleton pled guilty to being a felon in possession of firearms and ammunition. The district court found that Middleton was subject to enhanced sentencing under the Armed Career Criminal Act, ...

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