US v. Wright: Wright got involved in a fight at a nightclub in South Carolina, which led the crowd inside to pour out into the parking lot. Wright grabbed an AK-47 from a car and "sprayed 22 rounds" into the parking lot, wounding one person and killing another (who was asleep in his car at the time). Wright was convicted of being a felon in possession of a firearm, determined to be an Armed Career Criminal, and sentenced to life in prison.
On appeal, Wright raised several challenges to his sentence, all of which the Fourth Circuit rejected. First, Wright argued that prior juvenile convictions that were used to trigger the ACCA enhancement violated Apprendi because the juvenile proceedings did not involve the right to a jury trial. Because a jury trial is not Constitutionally required in juvenile proceedings, there was no error in using the results of those proceedings to increase a later sentence. Second, Wright argued that his prior juvenile convictions, in which he committed burglaries during which he stole firearms, did not involve "the use or carrying of a firearm" - as required to be ACCA predicates - because the act of burglary was complete before he possessed the firearms. The court disagreed, concluding that such burglaries "involve" the firearms. Finally, Wright argued that district court erred by applying the cross-reference to the first degree murder Guideline. The court concluded that Wright acted "willfully, deliberately, maliciously, and with premeditation" and thus the cross-reference applied. Judge Gregory dissented on the last point, arguing that there was no evidence that Wright "had a premeditated design to effect the death of any person."