Marcus Crawley, aka Holyfield v. United States
SocialSecurity Securities Immigration
Whether a reviewing court may search plea documents for evidence of another predicate to sustain a § 924(c) conviction when that predicate was not proven beyond a reasonable doubt or admitted to by the defendant
QUESTION PRESENTED In United States v. Davis, 139 S. Ct. 2319 (2019), the Court held that 18 U.S.C. § 924(c)’s crime of violence residual clause was unconstitutionally vague. The question presented is: If a defendant pleaded guilty to a § 924(c) charge and a predicate crime of violence that is no longer valid after Davis, may a reviewing court search plea documents for evidence of another predicate to sustain the § 924(c) conviction when that predicate was not proven beyond a reasonable doubt or admitted to by the defendant?