United States v. Anton Fuller-Ragland, 931 F.3d 456

Fuller‑Ragland, a felon, was arrested in Michigan with two pistols; one 9mm pistol had a serial number described in the PSR as “partially obliterated.”
He pleaded guilty to being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)).
The PSR treated a prior Michigan unarmed‑robbery conviction (Mich. Comp. L. § 750.530) as a "crime of violence" under USSG § 2K2.1(a)(3), producing a base offense level of 22.
The PSR also applied a 4‑level enhancement under USSG § 2K2.1(b)(4)(B) for an altered/obliterated serial number; Fuller‑Ragland did not object to these guideline calculations in district court.
The district court awarded acceptance‑of‑responsibility credit, then imposed an upward variance to the statutory maximum (120 months) based on public protection, deterrence, and criminal history; Fuller‑Ragland appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mich. Comp. L. § 750.530 (unarmed robbery, as amended) is a "crime of violence" under USSG § 4B1.2(a)(1) (elements clause)	Fuller‑Ragland: the amended statute criminalizes conduct broader than the elements clause requires and does not necessarily require the threatened or used physical force that Johnson/Stokeling demand	Gov: Michigan law construes "putting in fear" as fear of physical injury; precedent shows the statute requires threatened/overcoming force consistent with Johnson/Stokeling	Court: § 750.530 (as amended) is a "crime of violence" under the elements clause because "putting in fear" requires fear of physical injury and thus the threatened use of physical force sufficient under Johnson and Stokeling; no plain error in guideline calculation
Whether the 4‑level enhancement for an altered/obliterated serial number (USSG § 2K2.1(b)(4)(B)) was plain error	Fuller‑Ragland: serial number was legible to the naked eye and traceable, so enhancement should not apply; proposes a "naked‑eye" legibility test	Gov: PSR described the number as "partially obliterated"; circuit and other circuits apply enhancement where numbers are partially damaged or harder to read even if later traceable	Court: No plain error—description as "partially obliterated" suffices under controlling precedent (altered/obliterated means materially less accessible); enhancement affirmed

Gall v. United States, 552 U.S. 38 (procedural‑reasonableness and sentencing error framework)
Vonner v. United States, 516 F.3d 382 (6th Cir. en banc) (review of unobjected‑to PSR findings and plain‑error standard)
Johnson v. United States, 559 U.S. 133 (definition of "physical force" as violent force capable of causing physical pain or injury)
Stokeling v. United States, 139 S. Ct. 544 (any force sufficient to overcome victim’s resistance satisfies the force requirement)
United States v. Chaney, 917 F.3d 895 (6th Cir. precedent treating earlier version of Michigan unarmed robbery as violent felony under ACCA)
United States v. Yates, 866 F.3d 723 (categorical approach and analysis of elements‑clause applicability)
United States v. Ford, 560 F.3d 420 (categorical approach explanation)