Sanchez

OPINION **

Sanchez was convicted of being a felon in possession of a firearm in violation of 18 U.S.C. § 922 (g). The government sought a sentence enhancement under the Armed Career Criminal Act, 18 U.S.C. § 924 (e)(1), which requires a minimum fifteen-year sentence if a defendant found guilty of being a felon in possession of a firearm under 18 U.S.C. § 922 (g) has at least three previous convictions for violent felonies. 1 The district court declined to sentence Sanchez under the Act. Two prior qualifying convictions were not disputed. The district court found Sanchez’s guilty plea to a 1971 federal manslaughter charge to be constitutionally invalid because Sanchez took a sedative on the day he pleaded guilty and did not consider Sanchez’s 1969 federal conviction for threatening the life of the President, which the government raised in a supplemental pleading. The government cross-appeals Sanchez’s sentence. We reverse.

The Supreme Court recently held a defendant does not have a statutory or constitutional right to collaterally attack the validity of prior state court convictions used for enhancement purposes under the Armed Career Criminal Act on any ground other than the…