U.S. Supreme Court Cites Model Penal Code

In Borden v. United States, No. 19-5410 (June 10, 2021), the U.S. Supreme Court held that a criminal offense that requires only a mens rea of recklessness does not constitute a “violent felony” for purposes of an enhanced sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e).

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