United States v. Hoyle, 751 F.3d 1167 (10th Cir. May 13, 2014)

The Tenth Circuit rejected the defendant’s argument that the sentencing guidelines’ use of the term “imprisonment for a term exceeding one year” impermissibly deviated from 18 U.S.C. § 921(a)(20)’s definition of “crime punishable by imprisonment for a term exceeding one year.” The latter expressly excludes convictions that have been expunged, or set aside, or for which the defendant has had his civil rights restored; whereas the former includes such convictions. The Tenth Circuit held that the sentencing guidelines’ definition and the statutory definition have different purposes and need not be consistent.