The Eighth Circuit has affirmed a fifteen-year mandatory minimum sentence for a felon-in-possession defendant whose prior Minnesota conviction for third-degree murder was used to enhance his Sentencing Guidelines range. The defendant argued the district court erred in treating his 2012 conviction as a "crime of violence" under U.S.S.G. § 4B1.2(a).
Adopting the Third Circuit's definition of generic murder as encompassing intentional killing, killing during a dangerous felony, or killing through reckless and depraved indifference to human life, the Court held that Minnesota's third-degree murder statute, which criminalizes causing death through an act "eminently dangerous to others" showing a "depraved mind," substantially corresponds to that generic definition. Because the conviction qualified as murder under the enumerated offenses clause, the Court did not need to consider whether it also satisfied the Guidelines' separate force clause.
Although this is a criminal sentencing matter, it is likely to be persuasive when analyzing whether convictions qualify as aggravated felonies related to murder in the immigration context.
The full text of United States v. Hayden can be found here: https://ecf.ca8.uscourts.gov/opndir/26/07/251880P.pdf