The Seventh Circuit rejected a federal collateral attack where the Defendant was sentenced as an armed career criminal based (in part) on an Illinois attempt first degree murder conviction.
The Seventh Circuit held, apparently for the first time, that when a substantive offense would be a violent felony under §924(e) and similar statutes, an attempt to commit that offense also is a violent felony.
The Defendant argued that murder is not a violent felony for ACCA purposes, so the attempt shouldn’t be either. This was rejected.
The case is USA v. Hill.