United States v. John Mekediak, 510 F. App'x 348

Mekediak pled guilty to one count of being a felon in possession of a firearm in August 2011 under a plea agreement.
The PSIR recommended 262–327 months and classified Mekediak as an armed career criminal based on prior offenses.
Predicates included a 2003 drug offense, a 1999 unarmed robbery, and two 1995 juvenile delinquencies (short-barreled rifle, felonious assault).
The PSIR set base offense level at 24 and recommended a four-level enhancement for using a firearm with another felony (Minnesota transaction).
He was sentenced to 240 months; objections to ACCA status, base level, and enhancement were preserved and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can juvenile delinquencies form ACCA predicates when combined	Mekediak argues juveniles cannot be aggregated to meet ACCA.	US contends combined juvenile acts can satisfy ACCA.	Juvenile delinquencies cannot be combined to form ACCA predicate
Is unarmed robbery a crime of violence for USSG base level	Mekediak contests its use for base level 24.	US argues unarmed robbery fits the crime-of-violence residual clause.	Unarmed robbery qualifies as crime of violence for base level 24
Validity of four-level enhancement based on Minnesota transaction	Mekediak argues proffer agreement and interview timing taint evidence.	Government shows independent evidence supports enhancement.	Four-level enhancement upheld

Taylor v. United States, 495 F.3d 575 (1990) (establishes categorical vs. modified approach framework)
Begay v. United States, 553 U.S. 137 (2008) (limits residual clause scope for violent felonies)
Shepard v. United States, 544 U.S. 13 (2005) (defines modified categorical approach parameters)
United States v. Wells, 473 F.3d 640 (6th Cir. 2007) (juvenile adjudication analysis under modified categorical approach)
United States v. Armstead, 467 F.3d 943 (6th Cir. 2006) (reservations on broad use of Shepard documents)