Sentencing - Guidelines / Johnson / (ACCA)
Given govt stipulation that Guidelines residual clause is unconstitutionally vague Post-Johnson, an on-point note to the Guidelines doesn't save the predicate, as the note referred to an offense type that appears nowhere outside of the residual clause.
http://media.ca1.uscourts.gov/pdf.opinions/14-1216P-01A.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.