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153739P.pdf   01/10/2017  United States  v.  John Winston
   U.S. Court of Appeals Case No:  15-3739
   U.S. District Court for the Eastern District of Arkansas - Little Rock   
   [PUBLISHED] [Colloton, Author, with Melloy and Shepherd, Circuit Judges] 
   Criminal Case - sentence. District court properly counted Winston's prior 
   Arkansas conviction for second-degree battery under Ark.Code Ann. 
   5-13-202(a)(2) (1997) as a violent felony and concluded he had at least 
   three violent felonies or serious drug offenses to be subject to enhanced 
   punishment as an armed career criminal. Winston's contention that physical 
   injury is not the equivalent of physical force and the battery offense did 
   not contain element he used physical force is rejected.