Espinoza v. United States
Petition for certiorari denied on April 28, 2014
Issue: (1) Whether the Court should resolve the division between the circuits as to whether an offense with a mens rea of recklessness can trigger the sentence enhancement set out in 18 U.S.C. § 924(e)(2)(B)(ii), the residual clause of the Armed Career Criminal Act; and (2) whether an offense that requires only a mens rea of recklessness toward the act causing or risking injury can ever be “purposeful” as that term was used by this Court when interpreting § 924(e)(2)(B)(ii) in Begay v. United States.
