US v. Rivers: It's another blue light special in the Fourth Circuit. South Carolina has a felony offense of "failure to stop for a blue light" (i.e., not pulling over when the cops signal). In a case decided pre-Begay, the Fourth concluded that convictions for failure to stop for a blue light were "violent felon[ies]" under the Armed Career Criminal Act. In Roseboro, decided in the wake of Begay, the court concluded that convictions for failure to stop for a blue light would only be a violent felony in limited circumstances.
In this case, decided in the wake of the Supreme Court's decision in Chambers, the court finally resolved that "under no circumstances is a violation of South Carolina's blue light statute a violent felony under the ACCA." Specifically, the court held that the South Carolina statute applied to only one type of behavior and was thus not subject to the "modified" categorical approach as it did earlier in Roseboro.
Congrats to the FPD office in South Carolina on the win!