UNITED STATES OF AMERICA v. MARIO DELAINE - Articles

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UNITED STATES OF AMERICA v. MARIO DELAINE

Posted by: Azya Thornton on Apr 2, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Conrad Benjamin Kahn, FEDERAL DEFENDER SERVICES OF EASTERN TENNESSEE, INC., Knoxville, Tennessee, for Appellant.

Attorneys 2: Luke A. McLaurin, UNITED STATES ATTORNEY’S OFFICE, Knoxville, Tennessee, for Appellee.

Attorneys 3: ON BRIEF: Conrad Benjamin Kahn, FEDERAL DEFENDER SERVICES OF EASTERN TENNESSEE, INC., Knoxville, Tennessee, for Appellant.

Attorneys 4: ON BRIEF: Luke A. McLaurin, UNITED STATES ATTORNEY’S OFFICE, Knoxville, Tennessee, for Appellee.

Judge(s): GIBBONS, LARSEN, and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Tennessee at Chattanooga

MURPHY, Circuit Judge. The Armed Career Criminal Act requires a court to impose a minimum sentence of 15 years’ imprisonment for felons who possess firearms if they have three prior “violent felony” convictions. 18 U.S.C. § 924(e)(1). The statute defines the phrase “violent felony” in part to include an offense that “has as an element the use, attempted use, or threatened use of physical force against the person of another[.]” Id. § 924(e)(2)(B)(i). The district court in this case held that this definition covered three of Mario Delaine’s prior convictions and thus applied the 15-year minimum. Delaine has appealed. His appeal raises complex questions about the scope of the Armed Career Criminal Act. To name a few: When deciding whether a state-law offense qualifies as a “violent felony,” must a sentencing court look only to the state-law precedent at the time of a defendant’s conviction, or may it rely on later state-court decisions that clarify the offense’s elements? And can an offense qualify as a violent felony if the defendant intentionally uses force against another person but does not intend for the force to cause an injury? Despite the excellent advocacy of Delaine’s counsel, we disagree with him over the Act’s requirements and the nature of his prior offenses. Because all three of those offenses are violent felonies, we affirm.

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