United States v. Richard Douglas Travis, 747 F.3d 1312

Travis appeals a 96-month sentence after pleading guilty to felon in possession of a firearm.
At sentencing, district court assigned base offense level 24 under §2K2.1(a)(2) based on two prior “crimes of violence” under the residual clause of §4B1.2.
Priors: a 2006 Florida vehicular flight conviction under Fla. Stat. §316.1935(1) and a 2011 aggravated assault with a weapon conviction.
With a three-level acceptance-of-responsibility reduction, Travis had an adjusted offense level of 21 and a criminal history category VI, yielding a guideline range of 77–96 months.
Travis challenges treating the vehicular flight conviction as a crime of violence; the court proceeds under the categorical approach and ultimately holds the Florida §316.1935(1) offense qualifies as a crime of violence, affirming the sentence.
The court relies on Sykes v. United States and Petite to conclude that vehicle flight inherently poses a serious risk of physical injury to others.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §316.1935(1) vehicle flight is a crime of violence under the residual clause	Travis contends §316.1935(1) does not qualify	United States argues the statute presents a serious potential risk	Yes, it qualifies; sentence affirmed

Sykes v. United States, 131 S. Ct. 2267 (U.S. 2011) (vehicle flight poses serious risk of injury; residual clause analysis)
Petite v. United States, 703 F.3d 1290 (11th Cir. 2013) (simple vehicle flight poses serious risk; analogous to arson/burglary)
James v. United States, 550 U.S. 192 (U.S. 2007) (categorical approach to 'crime of violence')
United States v. Owens, 672 F.3d 662 (11th Cir. 2012) (ephemeral discussion of residual clause applicability)
United States v. Lockley, 632 F.3d 1238 (11th Cir. 2011) (de novo review of prior conviction as crime of violence)