United States v. Welch

The Eighth Circuit affirmed the district court's imposition of a sentencing enhancement under USSG 2K2.1(a)(4) because defendant had a previous conviction for Missouri second-degree assault that the district court determined was a crime of violence. The court held that Mathis v. United States, 136 S. Ct. 2243 (2016), did not change the court's previous holding that the Missouri second-degree assault statute was divisible because it defined multiple offenses. Defendant's conviction qualified as a crime of violence because he must knowingly cause physical injury to another person by means of a deadly weapon or dangerous instrument. View "United States v. Welch" on Justia Law