United States v. Jarnaro Middleton, 883 F.3d 485

Middleton pleaded guilty in 2005 to being a felon in possession of a firearm; at sentencing he was classified an armed career criminal under the ACCA and given a 15-year mandatory minimum based on three prior state convictions, including a 1980 South Carolina involuntary manslaughter conviction.
Middleton later sought post-conviction relief under § 2255 after Johnson (2015) invalidated the ACCA residual clause; the district court denied relief but issued a COA limited to whether the South Carolina involuntary manslaughter conviction qualifies as an ACCA "violent felony."
The Fourth Circuit reviewed the question de novo using the categorical approach: compare the elements of the state offense (using the least culpable conduct it criminalizes) to the ACCA force clause.
South Carolina involuntary manslaughter covers an unintentional killing without malice committed either during an unlawful non-felony act or during a lawful act with reckless disregard for safety (i.e., it can be based on recklessness); State v. Hambright illustrates a conviction based on selling alcohol to minors where a subsequent crash caused death.
The ACCA now defines "violent felony" only by (i) the force clause (use/attempted use/threatened use of physical force against another) and (ii) the enumerated offenses (burglary, arson, extortion, explosives) after Johnson (2015) struck the residual clause; the only question here is whether the force clause is satisfied.

Issue	Plaintiff's Argument (Middleton)	Defendant's Argument (Government)	Held
Does South Carolina involuntary manslaughter categorically qualify as an ACCA "violent felony" under the force clause?	The offense can be committed without the ACCA's required violent force (e.g., by selling alcohol to minors that later causes a fatal crash) and thus sweeps more broadly than the force clause.	Causing death necessarily entails applying physical force; Castleman said one cannot cause bodily injury without applying force, so involuntary manslaughter must involve force sufficient for ACCA.	Reversed district court: involuntary manslaughter does not categorically qualify under the ACCA force clause because it can be committed through non-violent, reckless conduct (e.g., sale of alcohol to a minor).

Johnson v. United States, 559 U.S. 133 (2010) (ACCA "physical force" means "violent force" capable of causing pain or injury)
Castleman v. United States, 572 U.S. 157 (2014) (common-law "force" can include indirect or de minimis offensive touching for MCDV statute; bodily injury requires physical force in that context)
Johnson v. United States, 576 U.S. 591 (2015) (Johnson II) (invalidated ACCA residual clause as unconstitutionally vague)
Descamps v. United States, 570 U.S. 254 (2013) (categorical approach: offense that "sweeps more broadly" than federal definition cannot qualify)
United States v. Reid, 861 F.3d 523 (4th Cir. 2017) (ACCA "use of physical force" includes direct or indirect application when force is violent)
In re Irby, 858 F.3d 231 (4th Cir. 2017) (unlawful killing requires force capable of causing physical pain or injury; indirect application can qualify)
United States v. Torres-Miguel, 701 F.3d 165 (4th Cir. 2012) (distinguished use of force from mere causation; a crime may result in death without "use" of physical force)
United States v. Doctor, 842 F.3d 306 (4th Cir. 2016) (application of categorical approach and discussion of force-clause requirements)
United States v. Covington, 880 F.3d 129 (4th Cir. 2018) (noting Castleman did not abrogate Torres-Miguel’s causation aspect)