The Eighth Circuit has affirmed a felon-in-possession sentence enhanced based on a prior Missouri conviction for unlawfully exhibiting a weapon in an angry or threatening manner, rejecting the defendant's argument that the Supreme Court's decision in Delligatti v. United States undermined circuit precedent holding the offense a crime of violence.
The Court held that its prior decision in United States v. Pulliam already recognized, consistent with Delligatti, that the object of the required force must be a person, and that Missouri's own courts have equated exhibiting a weapon in the presence of others with an assault against those bystanders. The Court also found no clear error in the district court's identification of the specific subdivision of the divisible Missouri statute underlying the defendant's plea.
The full text of United States v. Verges can be found here: https://ecf.ca8.uscourts.gov/opndir/26/08/252033P.pdf