United States v. Stephen Lester, 17-5230

Stephen Lester was arrested in Tennessee, held in Hamilton County Jail, and a federal indictment charged him with being a felon in possession of a firearm (18 U.S.C. § 922(g)(1)).
The U.S. filed a detainer and Lester was transferred to federal custody by writ of habeas corpus ad prosequendum; he pleaded guilty to the federal firearm charge and remained in federal custody at the county jail awaiting federal sentencing.
While still in federal custody at the county jail, Tennessee tried and convicted Lester of first-degree/ felony murder and especially aggravated robbery and sentenced him to life for the murder; he remained at the local jail pending transfers and state sentencing on remaining counts.
Lester moved to dismiss the federal indictment under the Interstate Agreement on Detainers (IAD), arguing the federal-to-state transfers constituted prohibited “shuttling” under Article IV(e).
The district court denied the motion, holding the IAD’s anti-shuttling provision applies only after a prisoner has “entered upon a term of imprisonment” at the state facility to which he is ultimately assigned; Lester had not been so assigned.
The district court also treated Lester as an Armed Career Criminal under the ACCA based on prior Tennessee aggravated-robbery convictions and imposed the 15-year mandatory minimum (sentence resulted in 180 months total). Lester appealed both rulings.

Issue	Plaintiff's Argument (Lester)	Defendant's Argument (Government)	Held
Whether transfers from federal custody to state custody for trial violated the IAD’s anti-shuttling provision	Transfer back to state custody before federal proceedings concluded violated IAD and requires dismissal	IAD applies only after a prisoner has entered upon a term of imprisonment at the state facility to which he is ultimately assigned; Lester was only in temporary/local jail custody	Affirmed: No IAD violation because Lester had not been transferred to the state facility where he would serve his sentence (Taylor and Jenkins govern)
Whether Tennessee aggravated robbery (and attempt) qualify as ACCA violent-felony predicates	Aggravated robbery can be committed without violent physical force or recklessly, so it should not count as an ACCA predicate	Tennessee robbery/aggravated-robbery necessarily involves violent physical force and cannot be committed recklessly; Mitchell controls	Affirmed: Aggravated robbery qualifies as a violent felony under ACCA; Mitchell controls and Tennessee statutes require intentional/knowing conduct, not recklessness

United States v. Taylor, 173 F.3d 538 (6th Cir.) (IAD anti-shuttling triggered only when prisoner reaches the state facility to which ultimately assigned)
Jenkins v. United States, 394 F.3d 407 (6th Cir.) (clarifies IAD "entered upon a term of imprisonment" requires transfer to ultimate state facility)
Alabama v. Bozeman, 533 U.S. 146 (2001) (describes IAD purpose to minimize interruption of a prisoner’s ongoing prison term)
United States v. Mitchell, 743 F.3d 1054 (6th Cir.) (Tennessee robbery categorically requires violent physical force and is an ACCA predicate)
Johnson v. United States, 559 U.S. 133 (2010) ("physical force" means violent force capable of causing physical pain or injury)
Mathis v. United States, 136 S. Ct. 2243 (2016) (distinguishes elements vs. means analysis for categorical matches; discussed but held not to undermine Mitchell)
United States v. Ferguson, 868 F.3d 514 (6th Cir.) (panel cannot overrule prior circuit precedent)