Immigration
Does a conviction under Georgia's felony obstruction-of-an-officer statute qualify as a 'crime of violence' or 'violent felony'?
QUESTIONS PRESENTED FOR REVIEW I. Does a conviction under Georgia’s felony statute, OCGA § 16-10-24(b), qualify as either a “crime of violence” under the elements clause of the career offender Sentencing Guideline, USSG § 4B1.2(a)(1), or a “violent felony” under the elements clause of the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e)(2)(b)(i), when under a proper categorical analysis the least of the acts criminalized by § 16-10-24(b) does not require proof of the “use, attempted use, or threatened use of physical force against the person of another”? Il. Does a proper categorical analysis under this Court’s precedent in Johnson v. United States, 559 U.S. 133 (2010), and Moncrieffe v. Holder, 569 U.S. 184 (2013), require an examination of whether the least of the acts criminalized under the statute in question requires proof of the “use, attempted use, or threatened use of physical force against the person of another”? i PARTIES Jacoby Burns is the petitioner, who was the defendant-appellant below. The United States of America is the respondent, who was the plaintiff-appellee below. ii