United States v. Meeks
2012 U.S. App. LEXIS 159
6th Cir.2012Background
- Meeks was convicted at trial of felon in possession of a firearm and drug distribution; the district court sentenced him as a career offender under § 4B1.1 due to prior Kentucky felonies.
- Prior convictions include 2000 first degree wanton endangerment (two counts) and 2004 first degree complicity to traffic in a controlled substance.
- Meeks challenged whether the wanton endangerment convictions qualify as crimes of violence under § 4B1.1 or as a proper § 851-enhanced sentence.
- Court applies a categorical (and, if needed, modified-categorical) approach to determine if a prior conviction is a crime of violence; finds wanton endangerment qualifies.
- Court rejects Meeks’s § 851-based challenges, holding § 851 notice applies to statutory enhancements, not guideline enhancements; affirms the career-offender designation and sentence.
- Outcome: sentence affirmed as properly imposed as a career offender.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Kentucky first degree wanton endangerment convictions qualify as crimes of violence under § 4B1.1? | Meeks contends they do not. | Government contends they are crimes of violence. | Yes; convictions are crimes of violence. |
| Does § 851 require notice/challenge rights to support a § 4B1.1 sentence? | Meeks argues § 851 notice and § 851(b) rights were required. | § 851 applies only to statutory enhancements, not guideline enhancements. | § 851 does not apply; guideline sentence upheld. |
Key Cases Cited
- Begay v. United States, 553 U.S. 137 (U.S. 2008) (limits residual-clause reach; discusses purpose of Begay inquiry)
- Sykes v. United States, 131 S. Ct. 2267 (U.S. 2011) (redefines Begay inquiry, allows risk-level approach)
- McMurray v. United States, 653 F.3d 367 (6th Cir. 2011) (confirms mixed Begay approach; uses modified-categorical analysis)
- United States v. Gibbs, 626 F.3d 344 (6th Cir. 2010) (explains categorical approach to crimes of violence; use of Shepard/Facts where necessary)
- United States v. Ruvalcaba, 627 F.3d 218 (6th Cir. 2010) (defines crime of violence with respect to violent felonies; supports requirement of purposeful/violent conduct)
- LaCasse v. United States, 567 F.3d 763 (6th Cir. 2009) (illustrates fleeing/eluding as crime of violence under modified analysis)