I. After defendant Jesse Pawlak sold firearms to an undercover officer on four occasions, a grand jury indicted him on four counts of possessing a firearm or ammunition as a felon, in violation of 18 U.S.C. § 922(g)(1). He pleaded guilty on all counts. At sentencing, the district court calculated a base offense level of 26 pursuant to U.S.S.G. § 2K2.1(a)(l) because the offenses involved a “semiautomatic firearm that is capable of accepting a large capacity magazine,” and Pawlak had two prior “felony convictions of either a crime of violence or a controlled substance offense.” U.S.S.G. § 2K2.1(a)(l). One of Pawlak’s two qualifying felony convictions was an Ohio third-degree burglary offense, a “crime of violence,” see United States v. Coleman, 655 F.3d 480, 481 (6th Cir.2011) (<HOLDING>). Absent that qualifying conviction, his base
holding that burglary is violent felony holding that thirddegree burglary is a violent felony holding that ohios thirddegree burglary statute constituted a violent felony under the residual clause of the armed career criminal act holding that possession of sawedoff shotgun is violent felony as defined by armed career criminal act holding that the illinois crime of failure to report for imprisonment is not a violent felony for purposes of the armed career criminal act