United States v. Quantrell Reid
2017 U.S. App. LEXIS 11513
| 4th Cir. | 2017Background
- Quantrell Reid pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
- The presentence report identified three prior Virginia convictions labeled "Inflict Bodily Injury" (March 2004, April 2005, July 2005) and recommended ACCA treatment; the report did not list the statute number.
- At sentencing counsel for Reid confirmed the convictions were under Va. Code § 18.2-55 (knowingly and willfully inflicting bodily injury on correctional facility employees) but argued § 18.2-55 is no greater than common-law battery and thus not an ACCA predicate.
- The government argued § 18.2-55 requires intentional infliction of bodily injury and therefore satisfies ACCA’s "force clause" (use of physical force capable of causing pain or injury).
- The district court treated the convictions as § 18.2-55 violations, rejected Reid’s objection, and imposed the ACCA 15-year mandatory minimum sentence; Reid appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the presentence report’s failure to cite the statute deprived parties and court of notice | Report label "Inflict Bodily Injury" left court to inference and speculation | Government and court had clear understanding that convictions were under Va. Code § 18.2-55 | Rejected; counsel repeatedly identified § 18.2-55 at sentencing, so there was no uncertainty |
| Whether Va. Code § 18.2-55 categorically qualifies as an ACCA "violent felony" under the force clause | § 18.2-55 can be violated by indirect/nonforceful means (e.g., poisoning, causing slip) so it does not necessarily involve "use of physical force" | § 18.2-55 requires knowingly and willfully inflicting bodily injury, which necessarily involves force capable of causing pain/injury; indirect means still constitute use of physical force | Held that § 18.2-55 is a categorical ACCA predicate under the force clause because the statute requires knowingly and willfully inflicting bodily injury and Castleman and Johnson treat indirect causation as "use of physical force" |
Key Cases Cited
- Johnson v. United States, 559 U.S. 133 (definition of "physical force" in ACCA as force capable of causing physical pain or injury)
- United States v. Castleman, 572 U.S. 157 (indirect acts causing bodily injury can qualify as use of physical force)
- United States v. Torres-Miguel, 701 F.3d 165 (4th Cir.) (earlier distinction between indirect and direct applications of force; court explains its reasoning is superseded by Castleman)
- United States v. Doctor, 842 F.3d 306 (4th Cir.) (application of categorical approach to ACCA force-clause analysis)
- United States v. Winston, 850 F.3d 677 (4th Cir.) (deference to state courts’ interpretation of state offense elements)