United States v. Derrick Dajuan Hall, 714 F.3d 1270 (11th Cir. 2013). · Go Syfert
United States v. Derrick Dajuan Hall, 714 F.3d 1270 (11th Cir. 2013). Cases Citing This Book View Copy Cite
68 citation events (68 in the last 25 years) across 3 distinct courts.
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At page 1271 Reviewing district court findings for clear error29 citing cases[W]e may affirm for any reason supported by the record, even if not relied upon by the district court.” (alteration in original) (quoting United States v. Chit-wood, 676 F.3d 971, 975 (11th Cir. 2012))4 citing courts put it this way · 28 listed here
  • United States v. Robert Kennedy, 146 F.4th 1054 (11th Cir. 2025).published
    ([W]e may affirm for any reason supported by the record, even if not relied upon by the district court.)
  • Mr. Mark Richard Hillstrom v. United States, No. 25-12950 (11th Cir. June 16, 2026).unpublished
    We “may affirm for any reason supported by the record.” United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013) (quoting United States v. Chitwood, 676 F.3d 971, 975 (11th Cir. 2012)).
  • United States v. Gregory Gallagher, No. 25-11272 (11th Cir. Feb. 13, 2026).unpublished
    See United States v. Campbell, 26 F.4th 860, 879 (11th Cir. 2022) (en banc); United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • Shoman Kasbekar v. Ivy Station Cmty. Ass'n, No. 20-10620 (11th Cir. Nov. 28, 2022).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Tauri Benjamin Rivas Nunez, No. 21-12512 (11th Cir. June 1, 2022).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Sam Henricy, No. 20-14161 (11th Cir. June 10, 2021).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Horace Cook, 998 F.3d 1180 (11th Cir. 2021).published
    It calls for no discretionary weighing or balancing by the district court and, as usual with questions of law, our review is de novo, see United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Ronald Johnson, No. 19-10340 (11th Cir. May 28, 2020).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Ronald Stansel, No. 18-10630 (11th Cir. Aug. 29, 2019).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Troy Anthony Coleman, No. 18-12946 (11th Cir. Apr. 8, 2019).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
Show 18 more citing cases
  • United States v. Curtis D. Huling, No. 17-13032 (11th Cir. July 10, 2018).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Carlos Antonio German, 680 F. App'x 841 (11th Cir. 2017).unpublished 2 cites
    We may affirm a sentence “for any reason supported by the record, even if not relied upon by the district court.” United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013) (quotation omitted).
  • United States v. Rico McKenzie, 663 F. App'x 806 (11th Cir. 2016).unpublished
    However, McKenzie fails to explain why the district court clearly erred in finding otherwise. - We review the district court’s factual findings for clear error, and “[w]e may affirm for any reason supported by the record, even .if not reli…
  • United States v. Sean Ghany, 652 F. App'x 748 (11th Cir. 2016).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Marcus Keith Brown, 627 F. App'x 912 (11th Cir. 2015).unpublished
    “We review de novo whether a defendant’s prior conviction qualifies as a crime of violence under the Guidelines.” United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013) (internal quotation marks omitted).
  • United States v. Walter Butler, Jr., 635 F. App'x 585 (11th Cir. 2015).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013). 5 .
  • United States v. Dioselis Fuentes-Nodarse, 606 F. App'x 475 (11th Cir. 2015).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • Gloria Sullivan v. Austal, USA, LLC, 569 F. App'x 728 (11th Cir. 2014).unpublished
    Here, the record provides a basis to determine whether Sullivan’s claims were frivolous, and we “may affirm for any reason supported by the record.” United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013); see also Hubbard v. BankAtlant…
  • United States v. Edward B. Hall, 567 F. App'x 896 (11th Cir. 2014).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • United States v. Louis B. Fussell, 567 F. App'x 869 (11th Cir. 2014).unpublished
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • United States v. Flornoy Smith, 742 F.3d 949 (11th Cir. 2014).published 2 cites
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • United States v. Timothy Eugene Kelly, 545 F. App'x 951 (11th Cir. 2013).unpublished 3 cites
    United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • United States v. Daniel McKinley, 732 F.3d 1291 (11th Cir. 2013).published
    Because we may affirm the district court on any ground supported by the record, United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013), we need not consider the district court’s alternative holding that the § 3C1.1 enhancement was also…
  • United States v. Christifa Knowles, No. 10-11809 (11th Cir. Apr. 6, 2020).unpublished
    (We may affirm the district court “for any reason supported by the record.” (citation omitted))
  • United States v. Dennis Michael Wilkerson, 702 F. App'x 843 (11th Cir. 2017).unpublished
    See United States v. Hall, 714 F.3d 1270, 1271 (11th Cir. 2013).
  • United States v. Jose Carmona, 625 F. App'x 963 (11th Cir. 2015).unpublished 2 cites
    See United States v. Hall, 714 F.3d 1270, 1271 (11th Cir.2013).
  • Veldora Arthur v. JP Morgan Chase Bank, N.A., 569 F. App'x 669 (11th Cir. 2014).unpublished
    (noting that this Court “ ‘may affirm for any reason supported by the record, even if not relied upon by the district court’ ” (quoting United States v. Chitwood, 676 F.3d 971, 975 (11th Cir. 2012)))
  • Wilson v. Warden, 834 F.3d 1227 (11th Cir. 2016).published 2 cites
    ([W]e may affirm for any reason supported by the record, even if not relied upon by the district court.” (alteration in original) (quoting United States v. Chit-wood, 676 F.3d 971, 975 (11th Cir. 2012)))
At page 1274 Determining crime of violence under sentencing guidelines9 citing casesconcluding that possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861 (d), qualifies as a “crime of violence” under U.S.S.G. § 4B1.2(a)(2) based on the binding guidelines commentary2 citing courts put it this way · 8 listed here
  • United States v. Alexis Valdes Gonzalez, No. 17-14583 (11th Cir. Nov. 13, 2018).unpublished
    The Burgest Court added that “we have recognized, based on the decision of the Supreme Court in Stinson v. United States, that ‘the definition of ‘crime of violence’ provided by the Guidelines commentary is authoritative.’” Id. (quoting Un…
  • United States v. Jorge Hernandez, No. 16-17349 (11th Cir. Sept. 26, 2018).unpublished
    United States v. Hall, 714 F.3d 1270, 1274 (11th Cir. 2013).
  • United States v. Jonathan Claret, 713 F. App'x 863 (11th Cir. 2017).unpublished
    United States v. Hall, 714 F.3d 1270, 1274 (11th Cir. 2013).
  • In re Earl Burgest, 829 F.3d 1285 (11th Cir. 2016).published
    And we have recognized, based on the decision of the Supreme Court in Stinson v. United States, 508 U.S. 36, 38 , 113 S.Ct. 1913, 1915 , 123 L.Ed.2d 598 (1993), that “the definition of “crime of violence” provided by the Guidelines comment…
  • Denson v. United States, 804 F.3d 1339 (11th Cir. 2015).published 2 cites
    (concluding that possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861 (d), qualifies as a “crime of violence” under U.S.S.G. § 4B1.2(a)(2) based on the binding guidelines commentary)
  • Travis Beckles v. United States, 616 F. App'x 415 (11th Cir. 2015).unpublished
    See U.S.S.G. § 4B1.2 cmt. n. 1 (providing expressly that the unlawful possession of “a firearm described in 26 U.S.C. § 5845 (a) (e.g., a sawed-off shotgun or sawed-off rifle, silencer, bomb, or machine gun) is a ‘crime of violence.’ ”); H…
  • Tony Edward Denson v. United States, 569 F. App'x 710 (11th Cir. 2014).unpublished
    (concluding that possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861 (d), qualifies as a “crime of violence” under U.S.S.G. § 4B1.2(a)(2) based on the binding guidelines commentary)
  • United States v. Darryl Rollins, No. 13-1731 (7th Cir. Sept. 1, 2015).published
    See, e.g., United States v. Hall, 714 F.3d 1270, 1274 (11th Cir. 2013); United States v. Hood, 628 F.3d 669 (4th Cir. 2010); United States v. Lipscomb, 619 F.3d 474 , 477–78 (5th Cir. 2010); United States v. Hawkins, 554 F.3d 615 (6th Cir.…
At page 1273 Applying three-step test for crime of violence5 citing cases“the analysis for the term 'crime of violence' is exactly the same because the two definitions are virtually identical”3 citing courts quote it
  • United States v. Ledell L. Ellis, No. 19-10156 (11th Cir. July 11, 2023).unpublished
    (holding prior conviction for possession of sawed-off shotgun qualified as a “crime of violence” under Guidelines even though it is not a “violent felony” under the ACCA)
  • United States v. Mikel Alemin Craig, 706 F. App'x 545 (11th Cir. 2017).unpublished 2 cites
    United States v. Hall, 714 F.3d 1270, 1273 (11th Cir. 2013).
  • United States v. Soto-Rivera, 811 F.3d 53 (1st Cir. 2016).published
    In the pre-Johnson Hall case, the Eleventh Circuit was “asked to decide whether an offense [i.e., possession of a sawed-off shotgun] qualifies as a ‘crime of violence’ under the [Guidelines’s] residual clause.” Hall, 714 F.3d at 1273 (emph…
  • Denson v. United States, 804 F.3d 1339 (11th Cir. 2015).published 2 cites
    United States v. Hall, 714 F.3d 1270, 1274 (11th Cir. 2013) (concluding that possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861 (d), qualifies as a “crime of violence” under U.S.S.G. § 4B1.2(a)(2) based on th…
  • Tony Edward Denson v. United States, 569 F. App'x 710 (11th Cir. 2014).unpublished
    United States v. Hall, 714 F.3d 1270, 1274 (11th Cir.2013) (concluding that possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861 (d), qualifies as a “crime of violence” under U.S.S.G. § 4B1.2(a)(2) based on the…
At page 1272 Defining crime of violence and violent felony under sentencing guidelines3 citing casescomparing ACCA “violent felony” definition to U.S.S.G. § 2K2.1(a)(2), which incorporates identical “crime of violence” definition from U.S.S.G. § 4B1.2(a)1 citing court put it this way
  • United States v. Donald John Bankston, III, 945 F.3d 1316 (11th Cir. 2019).published
    In fact, “commentary in the Sentencing Guidelines Manual that interprets or explains a guideline is authoritative unless it violates the Constitution or a federal statute, or is inconsistent with, or a plainly erroneous reading of, that gu…
  • United States v. Ihab Steve Barsoum, 763 F.3d 1321 (11th Cir. 2014).published 2 cites
    United States v. Hall, 714 F.3d 1270, 1272 (11th Cir.2013). ii.
  • United States v. Tedarel Leshun Preston, No. 18-12343 (11th Cir. Apr. 17, 2019).unpublished
    (comparing ACCA “violent felony” definition to U.S.S.G. § 2K2.1(a)(2), which incorporates identical “crime of violence” definition from U.S.S.G. § 4B1.2(a))
Other citing cases1 with no pin cite or quoted language on record
Retrieving the full opinion text from the archive…
UNITED STATES of America, Plaintiff-Appellee,
v.
Derrick Dajuan HALL, Defendant-Appellant
12-11343.
Court of Appeals for the Eleventh Circuit.
Apr 16, 2013.
Published opinion
714 F.3d 1270
2013 WL 1607612
2013 U.S. App. LEXIS 7597
Ramona Albin, Michael B. Billingsley, Praveen S. Krishna, Joyce White Vance, U.S. Attys., Birmingham, AL, Terrence Murphy O’Rourke, U.S. Atty., Huntsville, AL, for Plaintiff-Appellee., Rick Burgess (Court-Appointed), Kevin L. Butler, Fed. Pub. Defenders, James Tobia Gibson, Fed. Pub. Def., Huntsville, AL, for Defendant-Appellant.
Wilson, Cox, Voorhees.
Cited by 47 opinions  |  Published
WILSON, Circuit Judge:

Derrick Dajuan Hall appeals, his .37-month sentence after pleading guilty to being a felon in possession of a handgun, in violation of 18 U.S.C. § 922(g)(1). The district court enhanced Hall’s sentence under U.S.S.G. § 2K2.1(a)(4)(A) after determining that a prior 2006 felony conviction for possession of an unregistered sawed-off shotgun, in violation of 26 U.S.C. § 5861(d), qualified as a “crime of violence” under the Sentencing Guidelines. Following a three-level reduction for Hall’s acceptance of responsibility, the district court sentenced him to 37 months of imprisonment, at the top of the 30 to 37 month Guideline range. On appeal, we decide whether Hall’s sentence was properly enhanced by the prior conviction.

I.

The Sentencing Guidelines ascribe an enhanced Base Offense Level of 20 to a defendant who “committed any part of the instant offense subsequent to sustaining one felony conviction of ... a crime of violence.” U.S.S.G. § 2K2.1(a)(4)(A). ‘We review de novo whether a defendant’s prior conviction qualifies as a ‘crime of violence’ tinder the Guidelines.” United States v. Cortes-Salazar, 682 F.3d 953, 954 (11th Cir.2012), cert. denied, — U.S. -, 133 S.Ct. 995, 184 L.Ed.2d 772 (2013). “[W]e may affirm for any reason supported by the record, even if not relied upon by the district court.” United States v. Chitwood, 676 F.3d 971, 975 (11th Cir.) (internal quotation marks omitted), cert. denied, — U.S. -, 133 S.Ct. 288, 184 L.Ed.2d 169 (2012).

Section 4B1.2(a) of the Sentencing Guidelines defines a “crime of violence” as follows:

(a) The term “crime of violence” means any offense under federal or state law, punishable by imprisonment for a term exceeding one year, that—
(1) has as an element the. use, attempted use, or. threatened use of physical force against the person of another, or
(2) is burglary of a dwelling, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious potential risk of physical injury to another.

[*1272] U.S.S.G. § 4B1.2(a). The commentary to § 4B1.2 explicitly states that “[u]nlawfully possessing a firearm described in 26 U.S.C. § 5845(a) (e.g., a sawed-off shotgun or sawed-off rifle, silencer, bomb, or machine gun) is ' a ‘crime of violence.’ ” U.S.S.G. § 4B1.2 cmt. n. 1. The Sentencing Commission specifically amended the commentary to include this language in 2004, in an effort to give effect to the congressional determination that the “firearms described in 26 U.S.C. § 5845(a) are inherently dangerous and when possessed unlawfully, serve only violent purposes.” U.S.S.G. App. C, Amend. 674.

We have also elaborated generally on the “crime of violence” definition in our recent precedent:

As we explained in ... Chitwood, ... “under § 4B1.2 of the [Guidelines, any state or federal offense that is punishable by more than one year of imprisonment can be a crime of violence if it fits within one of three categories.” The first category of crimes, sometimes referred to as “elements clause” crimes, has as “an element the use, attempted use, or threatened use of physical force against the person of another.” U.S.S.G. § 4B1.2(a)(l). The second category includes the enumerated crimes of “burglary of a dwelling, arson, or extortion,” and those involving the “use of explosives.” Id. § 4B1.2(a)(2). The third category, sometimes referred to as “residual clause” crimes, includes those crimes that “otherwise involve conduct that presents a serious potential risk of physical injury to another.” Id.

Rozier v. United States, 701 F.3d 681, 682 n. 1 (11th Cir.2012) (alterations omitted). In addition, when determining whether an offense is a crime of violence, “we also rely on cases interpreting the residual clause of the Armed Career Criminal Act [ACCA], 18 U.S.C. § 924(e), because the § 4B1.2 definition of ‘crime of violence’ and ACCA’s definition of ‘violent felony’ are substantially the same.” Chitwood, 676 F.3d at 975 n. 2 [1] ; see Turner v. Warden Coleman FCI, 709 F.3d 1328, 1335 n. 4 (11th Cir.2013) (“The definition of ‘violent felony’ under the ACCA is virtually identical to the definition of ‘crime of violence’ for purposes of the career offender enhancement of § 4B1.1 of the United States Sentencing Guidelines (USSG), so that decisions about one apply to the other.” (internal quotation marks omitted)); Rozier, 701 F.3d at 682 n. 3 (quoting Chitwood, 676 F.3d at 975 n. 2); Gilbert v. United States, 640 F.3d 1293, 1309 n. 16 (11th Cir.2011) (en banc) (“Some of the listed decisions concern the definition of ‘violent felony’ in the ACCA, but we have held that term is ‘virtually identical’ to ‘crime of violence’ in § 4B1.1, so that decisions about one apply to the other.”); United States v. Archer, 531 F.3d 1347, 1350 n. 1 (11th Cir.2008). However, the Supreme Court has made clear that “commentary in the [Sentencing] Guidelines Manual that interprets or explains á guideline is authoritative unless it violates the Constitution or a federal statute, or is inconsistent with, or a plainly erroneous reading of, that guideline.” Stinson v. United States, 508 U.S. 36, 38, 113 S.Ct. 1913, 1915, 123 L.Ed.2d 598 (1993) (reversing the Eleventh Circuit’s previous holding that such[*1273] commentary was not binding on federal courts); see United States v. Beckles, 565 F.3d 832, 842 n. 1 (11th Cir.2009).

When, as here, we are asked to decide whether an offense qualifies as a “crime of violence” under the residual clause, we traditionally employ the three-step categorical approach established in Taylor v. United States, 495 U.S. 575, 602, 110 S.Ct. 2143, 2160, 109 L.Ed.2d 607 (1990), and further developed in Begay v. United States, 553 U.S. 137, 141-44, 128 S.Ct. 1581, 1584-86, 170 L.Ed.2d 490 (2008). [2] First, “we consider the offense generically, that is to say, we examine it in terms of how the law defines the offense and not in terms of how an individual offender might have committed it on a particular occasion.” Begay, 553 U.S. at 141, 128 S.Ct. at 1584. Second, we determine whether the generic offense “involves conduct that presents a serious potential risk of physical injury to another.” Id. at 141, 128 S.Ct. at 1584 (internal quotation marks omitted). Finally, if the offense does present such a risk, we classify it as a crime of violence only if it is “roughly similar, in kind as well as in degree of risk posed,” to the residual clause’s enumerated example crimes: burglary of a dwelling, arson, extortion, and the unlawful use of explosives. Id. at 143, 128 S.Ct. at 1585.

II.

Invoking Begay, Hall argues that his 2006 conviction for possession of an unregistered sawed-off shotgun does not qualify as a “crime of violence” because his conviction is not “roughly similar in kind” to the offenses enumerated in the residual clause of § 4B1.2(a)(2). Hall relies on our cases analyzing the term “violent felony” under the ACCA, and contends that the analysis for the term “crime of violence” is exactly the same because the two definitions are virtually identical. Hall specifically looks to our holding in United States v. McGill, 618 F.3d 1273 (11th Cir.2010) (per curiam), in which we determined that under the ACCA, á prior conviction for mere possession—rather than use—of 'a sawed-off shotgun “is not ‘similar in kind’ to [the] ‘use of explosives,’ its closest enumerated analog, or to the other crimes listed in the ACCA’s residual clause,” and therefore does not qualify as a violent felony. Id. at 1277. Hall further maintains that the Guidelines commentary does not merit substantial deference because, in light of United States v. Booker, 543 U.S. 220, 125 S.Ct. 738, 160 L.Ed.2d 621 (2005), the Guidelines are merely advisory. [3]

The government counters that the Guidelines commentary—explicitly listing[*1274] possession of an unregistered sawed-off shotgun as a “crime of violence”—is binding on us. The government argues that the cases analyzing “violent felony” under the ACCA are not controlling here because the text of the ACCA is silent on whether an unregistered sawed-off shotgun is a “violent felony,” unlike the commentary to § 4B1.2, which affirmatively lists possession of a sawed-off shotgun as a “crime of violence.”

We hold that Stinson controls, and that the definition of “crime of violence” provided by the Guidelines commentary is authoritative. Although we would traditionally apply the categorical approach to determine whether an offense qualifies as a “crime of violence,” we are bound by the explicit statement in the commentary that “[ujnlawfully possessing a firearm described in 26 U.S.C. § 5845(a) (e.g., a sawed-off shotgun or sawed-off rifle, silencer, bomb, or machine gun) is a ‘crime of violence.’ ” U.S.S.G. § 4B1.2 cmt. n. 1. Hall does not satisfy either of Stinson’s stringent exception requirements, as the commentary provision violates neither the Constitution nor any other federal statute, and it is not inconsistent with, or a plainly erroneous reading of, the guideline text itself. Moreover, because “the commentary to § [4B1.2] defines ‘crime of violence’ very differently than the ACCA does, ... we cannot say that the definition of ‘crime of violence’ provided in the commentary to § [4B1.2] is a plainly erroneous reading of the guideline.” Cortes-Salazar, 682 F.3d at 957.

We hold that possession of an unregistered sawed-off shotgun qualifies as a “crime of violence” under the Sentencing Guidelines, and we affirm Hall’s sentence.

AFFIRMED.

1

. The ACCA defines "violent felony” as "any crime punishable by imprisonment for a term exceeding one year ... that ... (i) has as an element the use, attempted use, or threatened use of physical force against the person of another; or (ii) is burglary, arson, or extortion, involves use of explosives, or otherwise involves conduct that presents a serious potential risk of physical injury to another.” 18 U.S.C. § 924(e)(2)(B). "The only difference in the second clause is that the ACCA includes 'burglary," ... and the Guidelines use ‘burglary of a dwelling.' ” United States v. Archer, 531 F.3d 1347, 1350 n. 1 (11th Cir.2008).

2

. Although the Supreme Court decided Begay in the context of the ACCA, the same categorical approach applies in the Sentencing Guidelines context. See Archer, 531 F.3d at 1350 n. 1.

3

. Hall also argues that under Begay’s "purposeful, violent, and aggressive” analysis, see 553 U.S. at 144-48, 128 S.Ct. at 1586-88, his "strict liability” conviction for mere possession of a sawed-off shotgun does not meet the definition of a "crime of violence.” However, "Begay's 'purposeful, violent, and aggressive’ analysis does not apply to offenses that are not strict liability, negligence, or recklessness crimes,” Chitwood, 676 F.3d at 979, and § 5861(d) offenses are not strict liability crimes because the government must prove the mens rea of knowledge. See United States v. Brantley, 68 F.3d 1283, 1289 (1995) (citing Staples v. United States, 511 U.S. 600, 114 S.Ct. 1793, 128 L.Ed.2d 608 (1994)) ("[I]n a prosecution for possession of an unregistered ... firearm under 26 U.S.C. § 5861(d), the government must prove beyond a reasonable doubt that the defendant knew that the firearm possessed characteristics bringing it within the scope of the statute.”). Therefore, Begay’s "purposeful, violent, and aggressive" analysis does not control here, and instead we only consider whether the prior conviction poses a serious potential risk of physical injury that is similar to the risk posed by one of the enumerated offenses. See Begay, 553 U.S. at 143, 128 S.Ct. at 1585.