United States v. Aemonn Alexander, 809 F.3d 1029

Alexander pled guilty to felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
District court sentenced him to 180 months under the Armed Career Criminal Act (ACCA) § 924(e)(1).
PSR found three qualifying prior convictions, including a Missouri Assault Second Degree conviction.
Alexander objected that Assault Second Degree under Mo. Rev. Stat. § 565.060 is not a violent felony under ACCA.
District court overruled the objection and applied the ACCA enhancement.
Appeal argues the conviction does not rest on a qualifying subpart, but court affirms the enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Assault Second Degree qualify as a violent felony under ACCA §924(e)(2)(B)(i)?	Alexander argues it does not qualify as a violent felony.	Government contends the conviction qualifies via the modified categorical approach.	Yes, it qualifies as a violent felony.
Does Reid control the analysis of the Missouri 'substantial step' for attempt-based assault under §565.060(1)(2)?	Alexander relies on Reid to limit the subsection analysis.	Government argues Reid does not control because the clause differs (not residual).	Reid does not control; Missouri's attempt statute supports the subpart (2) result under ACCA.

United States v. Cole, 778 F.3d 1055 (8th Cir. 2015) (de novo review of predicate offenses under ACCA)
Shepard v. United States, 544 U.S. 13 (Supreme Court 2005) (modified categorical approach allows examining the record to determine basis for conviction)
United States v. Vinton, 631 F.3d 476 (8th Cir. 2011) (applies modified categorical approach to §565.060.1(2))
State v. Williams, 126 S.W.3d 377 (Mo. 2004) (attempts require substantial step; does not overextend to negate ACCA)
State v. Faruqi, 344 S.W.3d 193 (Mo. 2011) (Missouri attempt statute and substantial step defined)
United States v. Reid, 769 F.3d 990 (8th Cir. 2014) (addresses residual clause and 'substantial step' in context of attempted burglary)