of any act which is within the scope of the lawful duty or authority of that officer, ... or who knowingly resists or obstructs the service or execution by any authorized person of any civil or criminal process or order of any court, commits a simple misdemeanor---However, if a person commits an interference with official acts, as defined in this subsection, and in so doing inflicts bodily injury other than serious injury, that person commits an aggravated misdemeanor. Iowa Code § 719.1(1). Because an aggravated misdemeanor under Iowa law carries the possibility of a two-year prison sentence, see Iowa Code § 903.1(2), it qualifies as a “prior felony conviction” for purposes of § 4B1.1, see USSG § 4B1.2, comment, (n.1). See United States v. Postley, 449 F.3d 831, 832 (8th Cir.2006) (<HOLDING>). To convict Malloy under section 719.1(1), a
holding that an aggravated misdemeanor conviction under section 7191 is a felony for purposes of assessing criminal history points under ussg  4a12c holding that conduct designated as a felony under state law but as only a misdemeanor under the controlled substances act does not qualify as an aggravated felony holding that drug felony under state law can constitute an aggravated felony for federal sentencing guidelines purposes even if the same conduct would not constitute a felony under federal law holding that a felony conviction in new york state court for possession of cocaine constituted an aggravated felony where the conviction would have also been punishable under the controlled substance act even though the crime would have only constituted a misdemeanor under federal law holding that conviction under  2702a3 or 4 is an aggravated felony under  101a43f