United States v. Quentin Jeffries, 822 F.3d 192

Quentin Lavelle Jeffries appealed his sentence; appointed counsel filed an Anders brief and moved to withdraw. The Fifth Circuit dismissed as frivolous and counsel was allowed to withdraw.
Jeffries filed a certiorari petition to the Supreme Court arguing his sentence relied on the Guidelines’ residual clause; the Solicitor General recommended remand for the circuit court to consider Johnson-related claims in the first instance.
The Supreme Court granted certiorari, vacated the Fifth Circuit judgment, and remanded for further consideration in light of Johnson v. United States.
The district court’s PSR (unchallenged by Jeffries) classified him as a career offender under U.S.S.G. § 4B1.1 based on two prior controlled-substance convictions and one aggravated-assault conviction under Texas Penal Code § 22.02.
U.S.S.G. § 4B1.2 defines “crime of violence” similarly to the ACCA’s “violent felony,” but Application Note 1 explicitly lists aggravated assault as a crime of violence.
The Fifth Circuit concluded Jeffries was sentenced as a career offender under the Guidelines, not under the ACCA or § 4B1.2’s residual clause, so Johnson provides him no relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Johnson’s invalidation of the ACCA residual clause invalidates Jeffries’s career-offender enhancement under the Guidelines	Jeffries argued his sentence relied on the Guidelines’ residual clause akin to ACCA’s clause	Government and PSR show he was a career offender based on enumerated offenses, not the residual clause	Held: No. Johnson does not afford relief because he was classified under § 4B1.1 using an enumerated offense
Whether Jeffries’s Texas aggravated-assault conviction is a qualifying "crime of violence"	Jeffries implicitly challenged the predicate status by invoking Johnson	PSR and Application Note 1 treat Texas aggravated assault (§ 22.02) as an enumerated crime of violence	Held: The aggravated-assault predicate is enumerated; therefore it qualifies and supports the career-offender designation

Anders v. California, 386 U.S. 738 (1967) (standards for appointed counsel’s Anders brief)
Flores v. United States, 632 F.3d 229 (5th Cir. 2011) (procedures for counsel withdrawal under Anders)
United States v. Jeffries, [citation="616 F. App'x 763"] (5th Cir. 2015) (prior Fifth Circuit disposition of this appeal)
Johnson v. United States, 135 S. Ct. 2551 (2015) (ACCA residual clause unconstitutional)
United States v. Guillen-Alvarez, 489 F.3d 197 (5th Cir. 2007) (treatment of application notes as defining guideline terms)
United States v. Guzman, 797 F.3d 346 (5th Cir. 2015) (analyzing Texas § 22.02 under ACCA force clause)