D. Mont. Recognizes that "Whether a Walk-Away Escape is a Violent Crime Under the ACCA is the Subject" of a Circuit Split
Per U.S. v. Smith, 2008 WL 4534021 n.2 (D. Mont. Oct 09, 2008):
The issue of whether a walk-away escape is a violent crime under the ACCA [Armed Career Criminal Act] is the subject of a split of authority within the circuits. See United States v. Springfield, 196 F.3d 1180, 1185 (C.A.10 1999) ("walkaway" escape from prison honor camp is a violent felony under ACCA). Furthermore, the Supreme Court recently granted certiorari to consider whether a conviction for escape under a statute that encompasses walkaway escapes qualifies as a crime of violence under the ACCA. United States v. Chambers, 473 F.3d 724 (7th Cir.2007), cert. granted, No. 06-11206, 128 S.Ct. 2046 (Apr. 21, 2008).