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173817P.pdf 07/08/2019 United States v. Kyle Boleyn
U.S. Court of Appeals Case No: 17-3817
and No: 18-1021
and No: 18-2248
and No: 18-2286
and No: 18-2562
U.S. District Court for the Northern District of Iowa - Waterloo
[PUBLISHED] [Loken, Author, with Grasz and Stras, Circuit Judges]
Criminal case - Sentencing. These five appeals raise a common issue:
whether a prior conviction under Iowa Code 124.401, which makes it
unlawful to manufacture, deliver or possess with intent to manufacture or
deliver, a controlled substance, qualifies as a predicate offense
warranting sentencing enhancements under the Armed Career Criminal Act,
the Controlled Substances Act, and the career offender provisions of the
Sentencing Guidelines if the Iowa law of aiding and abetting is overly
broad. Held: the convictions do qualify as predicate offenses under the
ACCA, the CSA and the Guidelines; the Iowa law of aiding and abetting is
substantially equivalent to, not meaningfully broader than, the standard
adopted by federal courts in applying 18 U.S.C. Sec. 2.