United States v. Charles Allen Hall
684 F. App'x 333
| 4th Cir. | 2017Background
- Charles Allen Hall was convicted in 2009 of being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)) and later classified as an Armed Career Criminal (ACCA), receiving a lengthy sentence.
- Hall challenged his ACCA designation in a 28 U.S.C. § 2255 motion, arguing two prior state convictions did not qualify as ACCA "violent felonies": South Carolina third-degree burglary and a North Carolina aiding-and-abetting assault on a police officer.
- The district court denied relief, concluding both prior convictions qualified as violent felonies; Hall appealed.
- The government conceded South Carolina third-degree burglary is not a violent felony under ACCA.
- The Fourth Circuit applied the categorical approach and governing Supreme Court precedent and held South Carolina third-degree burglary sweeps more broadly than generic burglary because its locational element includes vehicles, watercraft, and aircraft.
- The court vacated the ACCA-based sentence and remanded for resentencing; it did not decide whether the North Carolina assault conviction qualifies as an ACCA predicate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether S.C. third-degree burglary qualifies as ACCA "burglary" (an enumerated violent felony) | Hall: S.C. statute is broader than generic burglary and therefore cannot serve as an ACCA predicate | Government (initially): it qualified; later conceded it does not | The statute is broader than generic burglary (includes vehicles, watercraft, aircraft as locational means), so it is not an ACCA predicate; sentence vacated and remanded for resentencing |
| Whether Hall had the requisite three prior violent felonies for ACCA status | Hall: He did not, because at least one prior (S.C. burglary) is not a predicate | Government: He had three qualifying priors | Court held Hall did not have the required three ACCA predicates (vacated sentence); did not resolve the NC assault conviction issue |
Key Cases Cited
- Descamps v. United States, 133 S. Ct. 2276 (2013) (explains the categorical approach for determining whether a prior conviction matches a generic offense)
- Mathis v. United States, 136 S. Ct. 2243 (2016) (statutes that list alternative means, not alternative elements, are indivisible and may sweep more broadly than the generic offense)
- Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as unconstitutionally vague; left force and enumerated clauses intact)
- United States v. Gardner, 823 F.3d 793 (4th Cir. 2016) (defines the "force clause" requirement of violent force for ACCA purposes)