United States v. Antone T. Adams, 815 F.3d 1291

Adams was sentenced to 180 months under ACCA for possession of a firearm as a felon after pleading guilty.
The district court relied on two Florida convictions for fleeing or attempting to elude to classify Adams as an ACCA career offender.
The remaining requirements for ACCA enhancement included a third qualifying predicate conviction; the government acknowledged a fourth conviction was not relied upon for the enhancement.
Adams objected that the ACCA residual clause was unconstitutionally vague, which would affect the predicate status of the Florida convictions.
After Johnson v. United States (2015) invalidated the residual clause, the government conceded the Florida fleeing/elude offenses no longer qualify under ACCA, and the district court’s sentence based on them was erroneous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the ACCA residual clause unconstitutional under Johnson v. United States?	Adams argues the residual clause is vague.	Government concedes residual clause unconstitutional.	Yes; residual clause unconstitutional.
Do Adams’s Fla. §316.1935 fleeing/elude convictions qualify as ACCA predicates post-Johnson?	Fla. §316.1935 offenses used to qualify under ACCA.	Post-Johnson these offenses do not qualify as violent felonies.	No; cannot form ACCA predicate after Johnson.

Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as unconstitutionally vague)
United States v. Canty, 570 F.3d 1251 (11th Cir. 2009) (government may have one opportunity to argue enhancement at sentencing)