United States v. Bryan Chappell
2013 U.S. App. LEXIS 1962
| 8th Cir. | 2013Background
- Chappell pleaded guilty to possessing counterfeit currency (18 U.S.C. § 472) and felon in possession of a firearm (18 U.S.C. § 922(g)).
- District court calculated sentencing range 135–168 months but imposed a 240-month sentence under the Armed Career Criminal Act (ACCA) due to a 180-month minimum under § 924(e)(1).
- ACCA requires three prior convictions for a violent felony or a serious drug offense, or both, on occasions different from one another.
- Chappell had a 1991 drug offense and burglary, arson, and murder convictions arising from the same general timeframe; question whether these count as one or multiple predicate offenses.
- District court treated the murder as a separate predicate offense from burglary and arson; issue on appeal is whether these offenses occurred on different occasions.
- Court reviews the ACCA issue de novo and also considers the sentence's reasonableness under 18 U.S.C. § 3553(a); the panel affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are the 1991 murder and the burglary/arson convictions separate predicate offenses under the ACCA? | United States argues the offenses are distinct predicate episodes. | Chappell contends the offenses occurred on one occasion and should count as one. | Yes; murder is a separate predicate offense from burglary/arson. |
| Does Willoughby control whether these offenses count as separate predicate episodes? | United States relies on Willoughby as distinguishable or controlling in some respect. | Chappell argues Willoughby requires treating them as a single episode. | Willoughby is distinguishable; offenses occurred on different occasions and are separate predicate offenses. |
| Is the sentence substantively reasonable under the applicable standards? | Chappell argues the sentence is unreasonable as imposed. | District court acted within its discretion, considering history, characteristics, and testimony. | Yes; the sentence is substantively reasonable; no abuse of discretion. |
Key Cases Cited
- United States v. Mason, 440 F.3d 1056 (8th Cir. 2006) (discrete criminal episodes trigger ACCA predicate analysis)
- United States v. Hamell, 3 F.3d 1187 (8th Cir. 1993) (separate episodes despite short interval between crimes)
- United States v. Gray, 85 F.3d 380 (8th Cir. 1996) (discrete episodes, not continuous conduct, trigger ACCA)
- United States v. Petty, 828 F.2d 2 (8th Cir. 1987) (simultaneous crimes can count as a single episode)
- United States v. Davidson, 527 F.3d 703 (8th Cir. 2008) (distinction of separate occasions in ACCA context)
- United States v. Willoughby, 653 F.3d 738 (8th Cir. 2011) (distinguishes multi-offense scenarios in ACCA analysis)