Remand for Application of Chambers to Career Offender

U.S. v. Young, 2009 WL 886236 (4/3/09) (unpub'd) - Chambers applies to the interpretation of USSG § 4B1.2(a). The 10th remands to see if the defendant's escape was a failure to return escape and thus was not a "crime of violence" for purposes of determining the base offense level for a felon-in-possession of a firearm case under § 2K2.1. On the bad news side, a pre-instant-offense plea counted as a prior conviction for § 2K2.1, even though the defendant was not sentenced on that plea until after he committed the instant offense.