KS conviction for aggravated battery not a COV for guidelines purposes

US v. Adams, 40 F.4th 1162 (10th Cir. 2022) Mr. Adams’ sentence for unlawful possession of a firearm should not have been enhanced for having a prior crime of violence under USSG 2K2.1(a)(4). Mr. Adams had a prior conviction for aggravated battery under Kansas law. However, such a conviction does not qualify as a crime of violence because in Kansas an aggravated battery could stem from battery against a fetus, and the guidelines’ definition of a crime of violence doesn’t include battery against a fetus.