Travis Beckles v. United States, 579 F. App'x 833

Beckles, a federal prisoner, serves a 216-month sentence for possessing a sawed-off shotgun as a felon.
Beckles filed a counseled 28 U.S.C. § 2255 motion arguing his § 4B1.1 career-offender enhancement is improper because the shotgun offense is not a crime of violence.
The district court denied the motion, citing United States v. Hall, 714 F.3d 1270 (11th Cir. 2013).
On appeal, Beckles acknowledges Hall forecloses his claim but argues that Hall was wrongly decided.
The court reviews § 2255 issues de novo and is bound by prior panel decisions unless overruled by Supreme Court or en banc court.
The Eleventh Circuit affirms, holding Beckles’s claim fails under Hall.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Beckles’s possession of a sawed-off shotgun is a crime of violence under §4B1.2(a).	Beckles contends Hall is wrongly decided; possession should not be a crime of violence.	Hall controls; possession of an unregistered sawed-off shotgun qualifies as a crime of violence under §4B1.2(a).	Affirmed.

Begay v. United States, 553 U.S. 137 (2008) (definitional similarity to ACCA offenses for violent-felony classification)
McGill v. United States, 618 F.3d 1273 (11th Cir. 2010) (possession of a sawed-off shotgun not a violent felony under ACCA)
Hall v. United States, 714 F.3d 1270 (11th Cir. 2013) (possession of an unregistered sawed-off shotgun qualifies as crime of violence under §4B1.2(a))
Stinson v. United States, 508 U.S. 36 (1993) (guideline commentary binding unless unconstitutional or inconsistent)