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United States v. Lewis-Langston - ACCA Enhancement Harmless Error

The Fourth Circuit affirmed a defendant's 200-month ACCA-enhanced sentence for felon-in-possession of a firearm, finding that the district court erred under Erlinger v. United States by deciding at sentencing whether the defendant's three prior violent felonies were committed on different occasions. The court held this error was harmless because the defendant received adequate notice of potential ACCA exposure in his plea agreement and plea colloquy, did not seek to withdraw his guilty plea, and did not meaningfully contest the accuracy of his presentence report establishing the predicate offenses occurred on different dates. The court applied the harmless-error framework from United States v. Brown, 136 F.4th 87 (4th Cir. 2024), finding the evidence supporting the different-occasions finding was exceptionally strong.