UNITED STATES OF AMERICA v. JERROD LAQON MACK
US Court of Appeals for the Fourth Circuit, Niemeyer, May 1, 2017,
Crime of Violence- North Carolina convictions for attempting and conspiring to commit first-degree burglary qualify as crimes of violence under US Sentencing Guidelines

Facts:
Mack was convicted of possession of a stolen firearm and sentenced based in part on two prior North Carolina convictions for attempted burglary and conspiracy to commit burglary.
Mack challenged this conviction, arguing that the sentencing guidelines were vague and didn’t include attempts or conspiracies.

Law:
Held: The Court disagreed. Given the Supreme Court holding in Beckles, these sentencing guidelines cannot be considered unconstitutionally vague.