United States v. Eric Hall, 669 F. App'x 297

Defendant Eric Hall pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g).
The district court sentenced Hall to 180 months based on an Armed Career Criminal Act (ACCA) enhancement (15-year mandatory minimum) after finding four prior Tennessee convictions qualified as ACCA violent-felony predicates: burglary, robbery, and two aggravated burglaries.
Hall objected to using his burglary and robbery convictions below and challenged the aggravated-burglary predicates on appeal.
The Sixth Circuit has previously held Tennessee robbery is a violent felony, so the dispositive question is whether Tennessee aggravated burglary qualifies as an ACCA violent felony under the Supreme Court’s Mathis framework.
Both parties agreed remand was required in light of Mathis v. United States; the panel remanded but instructed the district court to hold the case in abeyance pending this circuit’s en banc decision in United States v. Stitt, which directly addresses whether Tennessee aggravated burglary counts as a generic violent felony.
The panel also vacated Hall’s written judgment because it included a supervised-release condition not imposed orally at sentencing and directed the district court to conform the final written judgment to the sentence pronounced at the hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tennessee aggravated burglary qualifies as an ACCA violent felony under Mathis	Hall argued the aggravated-burglary convictions should not be ACCA predicates under the Mathis categorical approach	Government argued aggravated burglary qualifies as a violent felony and supports ACCA enhancement	Court remanded for reconsideration under Mathis and ordered abeyance pending en banc decision in Stitt
Whether the written judgment’s supervised-release condition was proper	Hall argued the written condition was improper because it was not imposed orally	Government conceded inclusion was an abuse of discretion	Court vacated the judgment and directed the district court to ensure the written judgment matches the oral sentence

Mathis v. United States, 136 S. Ct. 2243 (U.S. 2016) (clarifies categorical approach for ACCA predicate analysis)
United States v. Taylor, 800 F.3d 701 (6th Cir. 2015) (held Tennessee robbery is an ACCA violent felony)
United States v. Carpenter, 702 F.3d 882 (6th Cir. 2012) (district court abuses discretion by adding conditions in written judgment not pronounced at sentencing)
United States v. Schultz, 855 F.2d 1217 (6th Cir. 1988) (procedural standards for conformity between oral sentence and written judgment)