In a post I put up at the beginning of the month, I suggested the Supreme Court’s recent Mathis decision raised doubt about the Ninth Circuit’s holding in Coronado v. Holder, 759 F.3d 977 (9th Cir. 2014), that the California drug statutes are divisible. (See “Mathis May Open Up More Doors Than You Think” in […]
Read/Write CommentsBLOG BULLETS: The new amendment narrowing the “crime of violence” definition in the career offender guideline took effect August 1. The amendment eliminates burglary of a dwelling from the definition, eliminates the residual clause, and narrows the definition of extortion in a way that probably undercuts a prior Ninth Circuit decision in United States v. […]
Read/Write CommentsBLOG BULLETS: Mathis not only upholds Rendon but raises doubt about the Ninth Circuit’s holding in Coronado v. Holder, 759 F.3d 977 (9th Cir. 2014), that the overbroad California drug statutes are divisible. One line of attack is Mathis’s citation of California Penal Code § 952 as an example of a state statute which courts […]
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