An 11th Circuit ruling on prior convictions and Shepard

In addition to all the recent discussion of reasonableness (detailed here), this week has also seen a lot of circuit discussion of criminal history issues.  In addition to the work of the 5th Circuit in Gutierrez-Ramirez (discussed here) and the 10th Circuit in Garcia-Rodriguez (discussed here), today the 11th Circuit handed down US v. Orduno-Mireles, No. 04-12630 (11th Cir. Apr. 6, 2005) (available here), which concerned whether certain prior convictions qualified as crimes of violence for purposes of a guideline enhancement.  The Eleventh Circuit affirms the defendant’s sentence in Orduno-Mireles after discussing at some length a number of Shepard and Booker issues and the “prior conviction exception.”