The U.S. Court of Appeals for the Eighth Circuit ruled that a federal district court incorrectly applied a sentence enhancement under the Armed Career Criminal Act, vacating the sentence of Darrick Lynn Ferguson and ordering a new sentencing hearing.
Ferguson was convicted of being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) after pleading guilty to the charge. The case centers on whether Ferguson's prior criminal history qualified him for enhanced punishment under the Armed Career Criminal Act, which significantly increases prison terms for repeat offenders.
The district court in the Eastern District of Arkansas initially determined that Ferguson qualified for the ACCA enhancement based on three prior felony convictions. One of those convictions was under Arkansas Code Ann. Section 5-64-401(a)(1)(A)(i) for delivery of a controlled substance, specifically cocaine. The district court concluded that this conviction, along with Ferguson's other prior felonies, met the requirements for enhanced sentencing under 18 U.S.C. § 924(e).
The Armed Career Criminal Act requires a mandatory minimum sentence of at least 15 years in prison for defendants convicted of being a felon in possession of a firearm who have three or more prior convictions for "serious drug offenses." The law is designed to impose harsher penalties on career criminals who repeatedly commit serious crimes involving drugs or violence.
On appeal, Ferguson challenged the district court's determination that he qualified for the ACCA enhancement. His legal team argued that his prior convictions did not meet the statutory requirements for the enhanced sentencing provisions. The Eighth Circuit Court of Appeals agreed with Ferguson's position.
Circuit Judge Gruender wrote the opinion for the three-judge panel, which also included Circuit Judges Smith and Shepherd. The court found that the district court erred in its analysis of Ferguson's prior convictions and their qualification under the ACCA's definition of "serious drug offense."
The appeals court's decision highlights the ongoing complexity courts face in applying ACCA enhancements. Federal courts must carefully analyze each prior conviction to determine whether it meets the specific statutory criteria for enhancement. This often involves examining the elements of state crimes and comparing them to federal standards.
For a state drug offense to qualify as a "serious drug offense" under the ACCA, it must meet specific federal criteria. Courts must conduct what is known as a "categorical approach," looking at the statutory elements of the prior conviction rather than the specific facts of what the defendant actually did.
The Eighth Circuit's reversal means Ferguson will face a new sentencing hearing in the district court. Without the ACCA enhancement, Ferguson's potential sentence would be significantly reduced from the mandatory minimum of 15 years that would have applied under the enhanced sentencing provisions.
This case reflects broader trends in federal criminal law regarding the application of sentencing enhancements. The Supreme Court and various circuit courts have issued numerous decisions in recent years clarifying when prior state convictions qualify for federal sentence enhancements, often resulting in more restrictive interpretations that benefit defendants.
The ruling also demonstrates the importance of thorough appellate review in criminal cases involving complex sentencing provisions. Ferguson's successful appeal prevented him from serving what could have been many additional years in federal prison based on an incorrect legal determination.
Federal prosecutors in cases like Ferguson's must prove that each prior conviction relied upon for enhancement purposes meets the strict statutory requirements. When courts find that prosecutors have not met this burden, defendants benefit from reduced sentences that reflect their actual criminal history rather than an inflated assessment of their prior record.
The case was submitted to the Eighth Circuit on Sept. 19, 2025, and the court filed its opinion on Jan. 6, 2026. The relatively quick resolution suggests the legal issues were well-developed in the parties' briefing and oral arguments.
Ferguson's case will now return to the Eastern District of Arkansas for resentencing without the ACCA enhancement. The district court will need to calculate an appropriate sentence based on Ferguson's actual criminal history and the standard federal sentencing guidelines that apply to felon-in-possession cases.
The decision serves as a reminder that even after pleading guilty and being sentenced, defendants retain the right to challenge legal errors that may have resulted in unlawfully enhanced punishments. Ferguson's successful appeal demonstrates the value of competent appellate representation in complex federal criminal cases involving sentencing enhancements.