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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.