Armed Career Criminal Prior not valid

U.S. v. Gilbert, No. 05-3111 (7th Cir. September 19, 2006).

Sentence as an armed career criminal for possession of a firearm by a felon is vacated and remanded where the district court erred in treating defendant's prior conviction for criminal confinement as a conviction for a crime of violence since the record did not disclose that defendant was convicted of a form of criminal confinement that required a finding of force or threat of force. http://caselaw.lp.findlaw.com/data2/circs/7th/053111p.pdf