His practice is dedicated to federal and state civil and criminal appeals. Reviewing de novo, the First Circuit held that Mr. Soto was improperly designated as a Career Offender because his felon in possession conviction was not “a crime of violence.” The Government initially argued that a felon in possession conviction constituted a “crime of violence” pursuant to the residual clause of U.S.S.G. § 4B1.2(a). According to the Guidelines, a “crime of violence” is “any offense” punishable by over one year of imprisonment that (1) “has as an element the use, attempted use, or threatened use of physical force against the person of another,” or (2) “is burglary of a dwelling, arson, or extortion, or otherwise involves conduct that presents a serious potential risk of physical injury to another.” The underlined portion is what is commonly referred to as the “residual clause.”