crimmigration.com

The intersection of criminal law and immigration law

  • Home
  • About César
  • Articles
  • Books
  • Book Tour
  • Talks & Media

SCOTUS: Vehicle flight is violent felony under ACCA

It took less than twenty-four hours before my brother Carlos Moctezuma García, one-half (along with my other brother Raúl) of García & García Law and patrocinador of this blog, fielded a question about whether last week’s Supreme Court decision holding that vehicle flight constitutes a violent felony under the Armed Career Criminal Act (ACCA) applies to the crime of violence type of aggravated felony. See Sykes v. United States, No. 09-11311, slip op. (June 9, 2011) (Kennedy wrote for Roberts, Breyer, Alito, Sotomayor; Thomas concurring in the judgment; Scalia dissented; Kagan dissented and Ginsburg joined). The likely answer is no.

It’s not a surprise that Sykes came onto the radar of some immigration law-minded folks. The ACCA imposes a serious sentencing enhancement if someone is convicted of being a felon in unlawful possession of a firearm after having been convicted of three previous violent felonies. 18 U.S.C. § 922(a)(2). The ACCA defines “violent felony” in language that closely resembles the crime of violence definition used by the INA’s aggravated felony provision.

The ACCA defines violent felony as an offense punishable by at least one year of imprisonment and that “(i) has as an element the use, attempted use, or threatened use of physical force against the person of another; or (ii) is burglary, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious potential risk of physical injury to another.” 18 U.S.C. § 924(e)(2)(B).

In comparison, INA § 101(a)(43)(F) defines a crime of violence by referencing 18 U.S.C. § 16 which, in turn, defines crime of violence as “(a) an offense that has as an element the use, attempted use, or threatened use of physical force against the person or prop­erty of another, or (b) any other offense that is a felony and that, by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.”

While the first prong of the ACCA’s definition and the definition used by the INA are almost identical, there is greater difference between the second prongs of each definition. While the ACCA’s second prong requires that the offense “involve[] conduct that presents a serious potential risk of physical injury to another,” 18 U.S.C. § 924(e)(2)(B)(ii), the definition that the INA uses requires “substantial risk that physical force…may be used,” 18 U.S.C. § 16(b).

The key difference is in the focus of each definition. The ACCA focuses on the likelihood that someone will be injured as a result of committing the offense. Sykes, No. 09-11311, slip op. at 6 (“The question, then, is whether Indiana’s prohibition on flight from an officer by driving a vehicle…falls within the residual clause because, as a categorical matter, it presents a serious potential risk of physical injury to another.”).

In contrast, the INA’s chosen definition focuses on the substantial risk that physical risk will be used during commission of the crime. Leocal v. Ashcroft, 543 U.S. 1, 11 (2004) (“This is particularly true in light of §16(b)’s requirement that the ‘substantial risk’ be a risk of using physical force against another person ‘in the course of committing the offense.’”).

The Leocal Court explained this distinction with regard to the definition of crime of violence used in the U.S. Sentencing Guidelines, a definition that is nearly identical to the ACCA’s definition: “Thus, §16(b) plainly does not encompass all offenses which create a “substantial risk” that injury will result from a person’s conduct. The ‘substantial risk’ in §16(b) relates to the use of force, not to the possible effect of a person’s conduct.” Leocal v. Ashcroft, 543 U.S. 1, 10 n.7 (2004).

Because the Sykes Court was considering the ACCA definition, its holding can be read to mean only that vehicle flight necessarily “‘involves conduct that presents a serious potential risk of physical injury to another.’” Sykes, No. 09-11311, slip op. at 11 (quoting 18 U.S.C. § 942(e)(2)(B)(ii)). This does not necessarily mean that fleeing with the use of a vehicle also necessarily involves a substantial risk of using physical force. Compare United States v. Charles, 301 F.3d 309, 314 (5th Cir. 2002) (explaining that an offense is a crime of violence under the U.S. Sentencing Guidelines § 4B1.2(a)(2) definition if the crime “presents a serious potential risk of injury to a person”), with Brieva-Perez v. Gonzales, 482 F.3d 356, 360 (5th Cir. 2007) (“Charles…does not extend to § 16 crime of violence cases….”).

Two possible complications appear. First, the Sykes Court explained in dicta that “Risk of violence is inherent in vehicle flight.” Sykes, No. 09-11311, slip op. at 7. This statement conceivably could be used no matter what the definition of crime of violence that applies is concerned—the ACCA or INA.

In a similar vein, the Court later wrote, “Serious and substantial risks are an inherent part of vehicle flight.” Sykes, No. 09-11311, slip op. at 12. This “substantial risk” language resembles the language of 18 U.S.C. § 16(b). However, my reading of this sentence alongside the prior paragraph of the opinion suggests that the Court was referring to the substantial risk of bodily injury. Courts might disagree with me, but that’s what I take from the decision’s reference to “substantial risk of bodily injury to another” just three sentences earlier. Sykes, No. 09-11311, slip op. at 12.

  • Share via Facebook
  • Share via LinkedIn
  • Share via Twitter
  • Share via Email

Share this:

  • Twitter
  • Facebook

Posted by César on June 14, 2011 on 9:00 am 106 Comments
Filed Under: ACCA, aggravated felony, crime of violence, U.S. Supreme Court

Comments

  1. Carlos Rosas says

    June 14, 2011 at 8:38 pm

    So do you believe the ice will try to use this decision in deportation proceedings? It seems as if the ACCA definition and the INS definition is one in the same for them. In terms of the Begay test it seems the court has changed it to only be applicable for reckless Crimes how does this affect the governments utilization of determining which crimes have the elements of 18(b)?

    Reply
  2. payday loans says

    January 12, 2013 at 11:54 pm

    payday loans

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  3. fast24hr-shorttermukloans.co.uk says

    March 22, 2013 at 8:55 pm

    fast24hr-shorttermukloans.co.uk

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  4. Uk1312Monthloans.Co.uk says

    April 5, 2013 at 5:09 pm

    Uk1312Monthloans.Co.uk

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  5. short term loans says

    April 8, 2013 at 5:32 pm

    short term loans

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  6. short term loans says

    April 8, 2013 at 8:09 pm

    short term loans

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  7. http://paydaynoloanshistoryonlinequickmh.co.uk/ says

    April 19, 2013 at 11:43 am

    http://paydaynoloanshistoryonlinequickmh.co.uk/

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  8. mobile bingo sites says

    May 12, 2013 at 1:32 am

    bingo mobile

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  9. credit consolidation loan reviews says

    May 12, 2013 at 2:12 am

    credit card consolidation loans

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  10. electronic cigarette vapor says

    May 12, 2013 at 3:11 am

    http://www.aboutecigarette.com

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  11. donald bernard uxbridge ma says

    May 12, 2013 at 3:17 am

    Donald Bernard

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  12. electronic cigarettes says

    May 12, 2013 at 3:25 am

    ecig

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  13. car valuation estimator says

    May 12, 2013 at 3:40 am

    car valuation free

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  14. hgh spray reviews says

    May 12, 2013 at 3:47 am

    hgh joint pain

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  15. wedding photographer rates says

    May 12, 2013 at 4:15 am

    San Diego wedding photographer

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  16. car valuation xing says

    May 12, 2013 at 4:43 am

    car valuation formula

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  17. how to get your ex girlfriend back says

    May 12, 2013 at 4:44 am

    how to get your ex back magic of making up

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  18. no contact rule says

    May 12, 2013 at 5:22 am

    http://www.sbwire.com/press-releases/wrelationshipcom-tells-visitors-how-to-get-their-ex-back-using-the-no-contact-rule-247419.htm

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  19. how to get your ex back says

    May 12, 2013 at 5:22 am

    http://www.sbwire.com/press-releases/wrelationshipcom-tells-visitors-how-to-get-their-ex-back-using-the-no-contact-rule-247419.htm

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  20. ecig says

    May 12, 2013 at 5:40 am

    electronic cigarette las vegas

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  21. garcinia max reviews says

    May 12, 2013 at 5:42 am

    garcinia pure

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  22. cheap car insurance says

    May 12, 2013 at 6:03 am

    car insurance florida

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  23. where can I buy 7 keto says

    May 12, 2013 at 6:06 am

    7 keto at walmart

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  24. http://www.speedycarvaluation.com says

    May 12, 2013 at 6:18 am

    car valuation

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  25. hghxpress says

    May 12, 2013 at 6:23 am

    hgh

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  26. donald bernard mitchell says

    May 12, 2013 at 6:28 am

    donald bernard newark nj

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  27. Phentermine diet pills says

    May 12, 2013 at 7:13 am

    Phentermine

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  28. hgh says

    May 12, 2013 at 8:02 am

    hgh natural

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  29. where can I buy 7 keto says

    May 12, 2013 at 8:17 am

    where can I buy 7 keto

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  30. testerone says

    May 12, 2013 at 8:44 am

    low t tribulus

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  31. 7 keto says

    May 12, 2013 at 8:51 am

    7 keto kullananların yorumları

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  32. donald g bernard says

    May 12, 2013 at 9:11 am

    donald bernard mitchell

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  33. credit card consolidation loans says

    May 12, 2013 at 9:13 am

    credit consolidation loans

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  34. http://www.ecigarretenews.com says

    May 12, 2013 at 9:30 am

    electronic cigarette yukon ok

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  35. how to get your ex back says

    May 12, 2013 at 9:39 am

    no contact rule

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  36. donald lee bernard says

    May 12, 2013 at 9:41 am

    Donald Bernard

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  37. electronic cigarette says

    May 12, 2013 at 9:44 am

    e cig

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  38. buy tramadol online says

    May 14, 2013 at 1:22 pm

    tramadol dosage for dogs

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  39. buy electronic cigarettes says

    May 14, 2013 at 1:28 pm

    buy electronic cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  40. tramadol online says

    May 14, 2013 at 1:33 pm

    tramadol online pharmacy

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  41. electronic cigarettes says

    May 14, 2013 at 1:33 pm

    vapor cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  42. buy e cigarette says

    May 14, 2013 at 1:34 pm

    electronic cigarettes queensland

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  43. provigil bulletproof says

    May 14, 2013 at 1:37 pm

    provigil

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  44. tramadol reviews says

    May 14, 2013 at 1:39 pm

    buy tramadol

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  45. buy modafinil says

    May 14, 2013 at 1:39 pm

    modafinil cost without insurance

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  46. vapor cigarettes says

    May 14, 2013 at 1:43 pm

    smokeless cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  47. garcinia pure says

    May 14, 2013 at 1:44 pm

    garcinia cambogia extract

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  48. e-cigs says

    May 14, 2013 at 1:55 pm

    e-cigs

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  49. electronic cigarettes tulsa ok says

    May 14, 2013 at 1:58 pm

    where to buy electronic cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  50. best e cigarette 2013 says

    May 14, 2013 at 2:00 pm

    best e cigarette 2013

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  51. cialis normal dosage says

    May 14, 2013 at 2:05 pm

    http://cialis-italia.com

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  52. buy tramadol says

    May 14, 2013 at 2:07 pm

    buy tramadol

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  53. vaporizer cvs says

    May 14, 2013 at 2:07 pm

    vaporizer inhaler

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  54. modafinil australia says

    May 14, 2013 at 2:12 pm

    modafinil purchase

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  55. electronic cigarettes miami says

    May 14, 2013 at 2:15 pm

    smokeless cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  56. lifelock promotional code says

    May 14, 2013 at 2:17 pm

    lifelock locations

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  57. volcano vaporizer says

    May 14, 2013 at 2:29 pm

    vaporizer xrt

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  58. garcinia pure says

    May 14, 2013 at 2:30 pm

    garcinia

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  59. electronic cigarettes online says

    May 14, 2013 at 2:43 pm

    vapor cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  60. best electronic cigarette says

    May 14, 2013 at 2:45 pm

    http://www.databytez.com/

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  61. cialis generico says

    May 14, 2013 at 2:49 pm

    cialis leg pain

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  62. best e cigs says

    May 14, 2013 at 2:51 pm

    electronic cigarettes krave

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  63. vaporizer makes me cough says

    May 14, 2013 at 2:59 pm

    vaporizer

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  64. london escort says

    May 14, 2013 at 3:11 pm

    london escorts

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  65. e cigarette coupons says

    May 14, 2013 at 3:19 pm

    v2 cigs coupon

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  66. vapor cigarettes says

    May 14, 2013 at 3:29 pm

    electronic cigarettes lexington ky

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  67. cialis generico says

    May 14, 2013 at 3:30 pm

    http://cialis-italia.com

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  68. garcinia pure says

    May 14, 2013 at 3:31 pm

    garcinia pure

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  69. http://cialis-italia.com says

    May 14, 2013 at 3:34 pm

    acquisto cialis

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  70. buy modafinil in australia online says

    May 14, 2013 at 3:36 pm

    modafinil tim ferriss

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  71. electronic cigarettes las vegas says

    May 14, 2013 at 3:42 pm

    electronic cigarettes during pregnancy

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  72. london escorts says

    May 14, 2013 at 3:44 pm

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  73. electronic cigarette coupons says

    May 14, 2013 at 3:45 pm

    electronic cigarette accessories

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  74. modafinil for sale says

    May 14, 2013 at 3:57 pm

    modafinil vs armodafinil

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  75. http://ecigre.tumblr.com says

    May 14, 2013 at 4:02 pm

    http://ecigre.tumblr.com

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  76. provigil zyprexa says

    May 14, 2013 at 4:09 pm

    provigil yahoo answers

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  77. Anonymous says

    May 14, 2013 at 4:10 pm

    london escort

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  78. lifelock iphone case says

    May 14, 2013 at 4:10 pm

    lifelock promo code

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  79. buy modafinil online says

    May 15, 2013 at 5:18 pm

    buy modafinil

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  80. garcinia pure says

    May 15, 2013 at 5:46 pm

    garcinia cambogia juice

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  81. http://runninggirls.co.uk says

    May 15, 2013 at 5:55 pm

    escorts london

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  82. cialis generico says

    May 15, 2013 at 6:28 pm

    acquisto cialis

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  83. provigil online says

    May 15, 2013 at 6:38 pm

    http://buyprovigil.webs.com

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  84. tramadol max dose says

    May 15, 2013 at 6:43 pm

    buy tramadol online

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  85. pax vaporizer says

    May 15, 2013 at 6:44 pm

    http://thevapechief.info

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  86. tramadol says

    May 15, 2013 at 7:01 pm

    tramadol online

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  87. vaporizer zephyr ion says

    May 15, 2013 at 7:06 pm

    volcano vaporizer

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  88. buy modafinil online says

    May 16, 2013 at 5:18 am

    modafinil

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  89. tramadol xanax says

    May 16, 2013 at 5:31 am

    tramadol

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  90. cialis says

    May 16, 2013 at 6:21 am

    cialis last longer

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  91. provigil says

    May 16, 2013 at 6:22 am

    buy provigil online

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  92. vaporizer no smell says

    May 16, 2013 at 6:32 am

    vaporizer at walmart

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  93. modafinil price says

    May 16, 2013 at 6:44 am

    modafinil usmle

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  94. christmas fern says

    May 16, 2013 at 6:45 am

    christmas board game

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  95. provigil testimonials says

    May 16, 2013 at 7:02 am

    provigil online

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  96. cialis soft tabs says

    May 16, 2013 at 7:04 am

    cialis vs viagra reviews

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  97. acquisto cialis says

    May 16, 2013 at 7:06 am

    cialis que es

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  98. lifelock promotion code says

    May 16, 2013 at 7:11 am

    lifelock promotional code

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  99. buy provigil says

    May 16, 2013 at 7:15 am

    xyrem provigil

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  100. website copywriting says

    May 17, 2013 at 1:43 am

    website copywriting

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  101. green coffee quezon city says

    May 17, 2013 at 2:24 am

    green coffee maxx reviews

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  102. phentermine says

    May 17, 2013 at 2:32 am

    phentermine

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  103. christmas rap says

    May 17, 2013 at 2:33 am

    board games

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  104. electric cigarette says

    May 17, 2013 at 3:19 am

    electronic cigarettes

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  105. dr david amron says

    May 17, 2013 at 3:54 am

    dr david amron

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply
  106. Thierry lasry says

    May 17, 2013 at 4:20 am

    ray ban hipster glasses

    crImmigration.com: SCOTUS: Vehicle flight is violent felony under ACCA

    Reply

Leave a Reply to testerone Cancel reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Subscribe


Recent Posts

  • Supreme Court says gap in conviction records hurts migrant
  • Abolish ICE
  • Federal court enjoins 100-day deportation pause
  • ICE issues enforcement priorities
  • Immigration possibilities & challenges
  • Criminal bars, policing changes, & meaningful reforms in proposed legislation

Search

Social Media

Blawg 100 Honoree

The information contained on these pages must not be considered legal advice and does not create an attorney-client relationship. This work by www.crImmigration.com is licensed under a Creative Commons Attribution 4.0 International License.