No. 22-1350 ___________________________

United States of America

Plaintiff - Appellee

v.

Catrell Ronald Green

Defendant - Appellant ____________

Appeal from United States District Court for the Southern District of Iowa - Central ____________

Submitted: January 9, 2023 Filed: June 8, 2023 ____________ Before KELLY, ERICKSON, and STRAS, Circuit Judges. ____________ STRAS, Circuit Judge.

Catrell Green received a 108-month sentence for possessing a firearm as a felon. Although he challenges the base-offense-level calculation, a four-level enhancement for possessing a firearm in connection with another felony offense, and the overall length of the sentence, we affirm. I.

A routine traffic stop led to a foot chase when the driver took off running. Left behind was Green, who was lying down in the backseat. After a nearly three- minute struggle, officers finally dragged him out of the car.

It turns out that there may have been a reason why Green stayed put. Stashed on the floor, underneath the passenger seat, was a Taurus 9-millimeter pistol. Just days earlier, Green had brandished what appeared to be the same gun in a Snapchat video. With the evidence against him mounting, he decided to plead guilty to a single felon-in-possession count rather than risk a trial. See 18 U.S.C. §§ 922(g)(1), 924(a)(2).

Multiple factors went into determining Green’s sentence. The base offense level came from his “two [prior] felony convictions of either a crime of violence or a controlled substance offense.” U.S.S.G. § 2K2.1(a)(1) (providing for a base offense level of 26 in these circumstances if the “semiautomatic firearm” he possessed was “capable of accepting a large[-]capacity magazine”). Everyone agreed that a prior possession-with-intent-to-deliver-marijuana conviction counted as one. See Iowa Code § 124.401(1)(d). A 2015 assault while displaying a dangerous weapon was the other. See Iowa Code §§ 708.1(2), 708.2(3) (2013).

The second factor was a four-level enhancement for possessing the gun “in connection with another felony offense.” U.S.S.G. § 2K2.1(b)(6)(B). The district court1 concluded that Green had interfered with official acts by resisting arrest while “armed.” Iowa Code § 719.1(1)(f). Application of a three-level reduction for acceptance of responsibility left him with a total offense level of 27, see U.S.S.G. § 3E1.1, which equated to 108 months in prison after a downward variance of 12 months, see id. § 5G1.1(a).

1 The Honorable Rebecca Goodgame Ebinger, United States District Judge for the Southern District of Iowa. -2- II.

A key component of any sentence is the base offense level—the starting point for the calculation. See U.S.S.G. § 1B1.1(a)(1), (2) (requiring the sentencing court to “[d]etermine the base offense level” for the “offense of conviction”). Here, two facts led to a base offense level of 26: the pistol found in the car had a “large[-]capacity magazine” and Green had “two [qualifying] felony convictions.” Id. § 2K2.1(a)(1). On appeal, he challenges only one of the two convictions, the “crime of violence.”

The Sentencing Guidelines define a “crime of violence” as a felony offense that “has as an element the use, attempted use, or threatened use of physical force against the person of another.” Id. § 4B1.2(a)(1); see United States v. Schneider, 905 F.3d 1088, 1090 (8th Cir. 2018). This definition may