First Circuit: US v. Barbosa

Deft did not make sufficient showing for a Franks hearing, as misstatement of ages and sizes didn't impugn the narrative, and forcible entry isn't an element of the state's crime of armed home invasion; nothing in a more full investigation of the victims' delay in reporting or checking the victims for outstanding warrants would have put the terms of the affidavit in doubt.

Given circuit precedent, ACCA predicates are valid, including a conviction with a maximum sentence under the terms of the statute, but within the statute's range when prosecuted in state court.

http://media.ca1.uscourts.gov/pdf.opinions/17-1284P-01A.pdf