Published on: Friday, August 3, 2018

On August 3, 2018, in United States v. Eshetu, No. 15-3020, the DC Circuit joined the Tenth Circuit and held that the residual clause of § 924(c) is void for vagueness. The court rejected the government’s request to abandon the categorical approach when addressing the residual clause of § 924(c), holding that it was bound by circuit precedent.

The Training Division provides resources on the categorical approach, crimes of violence, violent felonies, and other challenges to enhanced sentences based on predicate offenses, here.