DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
182400P.pdf 03/18/2019 United States v. Cornelius Coleman
U.S. Court of Appeals Case No: 18-2400
U.S. District Court for the Eastern District of Arkansas - Little Rock
[PUBLISHED] [Kelly, Author, with Benton and Melloy, Circuit Judges]
Criminal Case - Armed Career Criminal Act. On plain error review,
Coleman's prior Arkansas conviction for kidnapping under Ark. Code sec.
5-11-102 is overbroad and indivisible, as the nefarious purposes listed in
subsections (a)(1) through (a)(7) are means, not elements. Thus, the
statute does not qualify as a violent felony and Coleman does not have
three predicate offenses to be sentenced under the ACCA. The sentence is
reversed.