United States v. Cottrell, No. 10-4573 (6th Cir. June 12, 2012) (unpublished).
Panel of Judges Moore, Sutton, and Stranch.
Sixth Circuit cites United States v. Coleman, 655 F.3d 480 (6th Cir. 2011), to decide that the defendant's prior Ohio burglaries count for ACCA purposes. Coleman is discussed on this blog below (Aug. 25, 2011).
The interesting catch to the case is that the district court had determined pre-plea that the priors did not count. For those of you in Lexington at the Sixth Circuit Conference, you may remember the discussion of pre-plea determinations....
