Eleventh Circuit upholds armed career criminal sentence for Florida man despite challenge to gun law and prior drug convictions
ATLANTA, GA – The U.S. Court of Appeals for the Eleventh Circuit has affirmed the 204-month federal prison sentence of Samuel Storey, a Florida man convicted of possessing a firearm as a felon, after rejecting multiple constitutional and sentencing challenges, including under the Supreme Court’s 2024 Erlinger decision.
Storey pleaded guilty to violating 18 U.S.C. § 922(g)(1), and the district court enhanced his sentence under the Armed Career Criminal Act (ACCA) based on three prior Florida drug convictions. On appeal, Storey argued that the statute exceeded Congress’s Commerce Clause authority, violated the Second Amendment, and that the sentencing court erred under Erlinger v. United States by determining—without a jury—that his prior offenses occurred on different occasions.
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