United States v. Aneuri Manzueta, 709 F. App'x 934

Defendant Aneuri Manzueta pleaded guilty to conspiracy to possess with intent to distribute 5 kg or more of cocaine.
District court sentenced Manzueta to 262 months imprisonment and applied the career-offender enhancement under the Sentencing Guidelines.
Career-offender status requires two prior felony convictions for a crime of violence or controlled-substance offense.
Manzueta had a prior New York conviction for attempted second-degree robbery (N.Y. Penal Law § 160.10).
Manzueta challenged that prior as not qualifying as a "crime of violence" for the career-offender guideline.
The Eleventh Circuit reviewed de novo and affirmed, holding the attempted second-degree robbery conviction qualifies as a crime of violence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Manzueta's prior New York attempted second-degree robbery conviction qualifies as a "crime of violence" for career-offender purposes	Manzueta argued the attempted robbery conviction does not categorically qualify as a crime of violence	Government argued second-degree robbery necessarily involves use or threat of physical force and is an enumerated offense; attempt counts under the guideline commentary	Court held the conviction qualifies: second-degree robbery has an element of use/threat of force, robbery is enumerated, and attempt is included by guideline commentary; affirmed sentence

United States v. Gibson, 434 F.3d 1234 (11th Cir. 2006) (standard of review for career-offender classification)
United States v. Estrada, 777 F.3d 1318 (11th Cir. 2015) (de novo review of whether a prior conviction is a crime of violence)
United States v. Lockley, 632 F.3d 1238 (11th Cir. 2011) (robbery under state law qualifies as a crime of violence under the Guidelines)