On November 25,
2015, Charles Naylor II pleaded guilty to being a felon in possession of a firearm
and ammunition.[1] The district court found that Naylor’s four
prior convictions for Missouri second-degree burglary qualified as violent
felonies, so it subjected him to enhanced sentencing under the Armed Career
Criminal Act (ACCA) and imposed a sentence of 180-months in prison followed by
three years of supervised release.[2] The enhanced sentence was affirmed by a panel
of the United States Court of Appeals for the Eighth Circuit in March 2017.[3] On subsequent appeal, the Eighth Circuit, en
banc, vacated the sentence and remanded for resentencing, holding that
second-degree burglary, as defined in Missouri’s statute, does not constitute a
violent felony under the ACCA, overturning the precedent of United States v. Sykes.[4]
