Whether a criminal offense with a reckless mens rea qualifies as a 'violent felony' under the Armed Career Criminal Act, 18 U.S.C. § 924(e)

QUESTION PRESENTED Under the Armed Career Criminal Act, 18 U.S.C. § 924(e), a defendant convicted of violating 18 U.S.C. § 922(¢) who has three previous convictions for a serious drug offense or violent felony is subject to a fifteen-year mandatory minimum term of imprisonment. D.C. Code § 22-402 provides “every person convicted... of an assault with a dangerous weapon, shall be sentenced to imprisonment for not more than 10 years.” The D.C. Court of Appeals has held that the crime of assault with a dangerous weapon can be committed with a reckless mens rea. See Vines v. United States, 70 A.3d 1170, 1180 (D.C. 2013). The question presented is whether a criminal offense with a reckless mens rea qualifies as a “violent felony” under the Armed Career Criminal Act, 18 U.S.C. § 924(e).