Lomax v. United States
Petition for certiorari denied on February 21, 2023
Issues: (1) Whether, pursuant to Kisor v. Wilkie, courts are obligated first to determine whether a sentencing guideline is ambiguous before affording deference to the Sentencing Commission’s commentary interpreting the guideline; and (2) whether courts may defer to the Sentencing Commission’s commentary to U.S.S.G. § 4B1.2(a)(2) that expands the guideline's definition of “crime of violence," which includes only specified completed offenses, to include inchoate offenses.