Von Allen Randall v. United States

I. The Texas statutes defining Petitioner’s prior offenses explicitly prohibit conduct outside the ACCA’s “serious drug offense” and “violent felony” definitions. The lower courts applied the ACCA anyway because Petitioner did not prove to the courts’ satisfaction that Texas had prosecuted and convicted someone for the exact same crime whose actual conduct fell outside the relevant definitions. When analyzing a state statute under the categorical approach, and that statute is explicitly broader than the relevant federal definition, does the defendant bear a burden of proving that the state had convicted someone for non-qualifying conduct? I. Whether 18 U.S.C. § 922(g)(1) comports with the Second Amendment?