The Eighth Circuit has determined that Iowa minutes of evidence are not sufficiently reliable documents to be admitted under the Supreme Court's decision in Shepard v. United States.  Thus, a court may not consider the minutes of evidence as part of the modified categorical approach, unless the defendant expressly admits to the contents of the minutes as part of the plea proceeding.

The full text of United States v. Dittmar can be found here:

http://media.ca8.uscourts.gov/opndir/18/07/171850P.pdf

Comment