Steven Dotson v. United States
DueProcess HabeasCorpus Jurisdiction
If a defendant successfully challenges on collateral review one or more of the predicate convictions that the district court relied on to impose a sentence enhancement under the Armed Career Criminal Act (ACCA), may the Government substitute new predicate convictions on collateral review that it did not invoke at sentencing in order to maintain the ACCA enhancement?
QUESTION PRESENTED If a defendant successfully challenges on collateral review one or more of the predicate convictions that the district court relied on to impose a sentence enhancement under the Armed Career Criminal Act (ACCA), may the Government substitute new predicate convictions on collateral review that it did not invoke at sentencing in order to maintain the ACCA enhancement?