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U.S. v. Richardson

United States Court of Appeals, Eighth Circuit
Mar 2, 2006
439 F.3d 421 (8th Cir. 2006)

Summary

holding that multiple counts of conviction under § 922(g) arising out of a single act of possession of a firearm should be merged at sentencing into a single offense

Summary of this case from United States v. Carnes

Opinion

No. 04-3472.

Submitted: June 23, 2005.

Filed: March 2, 2006.

Appeal from the United States District Court for the District of Minnesota, Donovan W. Frank, J.

Daniel M. Scott, Federal Public Defender, Minneapolis, Minnesota, for appellant.

Lisa A. Biersay, Assistant U.S. Attorney, Minneapolis, Minnesota, for appellee.

Before LOKEN, HEANEY, WOLLMAN, ARNOLD, MURPHY, BYE, RILEY, MELLOY, SMITH, COLLOTON, GRUENDER, and BENTON, Circuit Judges.


We issued a panel opinion in this matter on November 4, 2005. The defendant filed for rehearing en banc on the limited issue set forth in Section V of that opinion, namely, whether a defendant, based upon a single act of possession, can be convicted and punished under both 18 U.S.C. § 922(g)(1) (felon in possession) and (g)(3) (drug user in possession). The government conceded that rehearing is appropriate and joined the defendant in his request for rehearing en banc. For the reasons set forth below, we grant the petition for rehearing and vacate Section V of our prior opinion. This grant of rehearing does not affect the other sections of our prior opinion.

We briefly summarize the facts relevant to the issue before the en banc court. Richardson was convicted of a single incident of possession of a firearm on February 4, 2003. At the time he possessed the firearm he was both a convicted felon and a drug user. The government charged Richardson in two separate counts, that is, one count of being a felon in possession of a firearm on February 4, 2003, and a separate count of being a drug user in possession of a firearm on the same date. Richardson argued that the counts of conviction for being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1) and being a drug user in possession of a firearm in violation of 18 U.S.C. § 922(g)(3) arose out of a single act of possession of a firearm and, therefore, should have been merged at sentencing into a single offense. The panel decision in this case affirmed the multiple convictions based on our controlling precedent in United States v. Peterson, 867 F.2d 1110 (8th Cir. 1989), abrogated on other grounds by Horton v. California, 496 U.S. 128, 110 S.Ct. 2301, 110 L.Ed.2d 112 (1990).

In Peterson, we held that separate convictions for § 922(g)(1) and § 922(g)(3) arising out of a single act of firearm possession were not multiplicitous. We now overrule Peterson and join all the other Circuits that have addressed this issue to hold that Congress intended the "allowable unit of prosecution" to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification, possessed more than one firearm, or possessed a firearm and ammunition. See Bell v. United States, 349 U.S. 81, 81, 75 S.Ct. 620, 99 L.Ed. 905 (1955) (describing the unit of prosecution test); see also, United States v. Verrecchia, 196 F.3d 294, 297-98 (1st Cir. 1999) (applying Bell to hold that a felon's possession of multiple firearms comprised a single offense); United States v. Dunford, 148 F.3d 385, 388-90 (4th Cir. 1998) (applying Bell to hold that the possession of multiple firearms and ammunition by a felon who was also an illegal drug user comprised a single offense); United States v. Cunningham, 145 F.3d 1385, 1398-99 (D.C. Cir. 1998) (applying Bell to hold that the possession of multiple firearms comprised only one offense barring proof that the firearms were obtained at different times or stored separately); United States v. Keen, 104 F.3d 1111, 1118-20 (9th Cir. 1996) (applying Bell to hold that a felon's possession of a firearm and ammunition comprised only one offense); United States v. Hall, 77 F.3d 398, 402 (11th Cir. 1996) (holding that a felon's simultaneous possession of a firearm and ammunition comprised only one offense); United States v. Munoz-Romo, 989 F.2d 757, 758-59 (5th Cir. 1993) (holding that the possession of a firearm by an illegal alien who was also a felon comprised only one offense); United States v. Throneburg, 921 F.2d 654, 657 (6th Cir. 1990) (holding that a felon's simultaneous possession of a firearm and ammunition comprised only one offense); United States v. Pelusio, 725 F.2d 161, 168-69 (2d Cir. 1983) (applying Bell to hold that the receipt of a firearm and ammunition comprised only one offense); United States v. Valentine, 706 F.2d 282, 292-94 (10th Cir. 1983) (applying Bell to hold that the simultaneous possession of more than one weapon constituted only one offense); United States v. Frankenberry, 696 F.2d 239, 244-45 (3d Cir. 1982) (applying Bell to hold that the receipt of multiple firearms comprised only one offense); United States v. Oliver, 683 F.2d 224, 232-33 (7th Cir. 1982) (applying Bell to hold that the simultaneous receipt of a firearm and ammunition comprised only one offense).

We remand to the district court to vacate the sentence, merge the counts of conviction into one count, and resentence the defendant based on a single conviction under 18 U.S.C. § 922(g).


Summaries of

U.S. v. Richardson

United States Court of Appeals, Eighth Circuit
Mar 2, 2006
439 F.3d 421 (8th Cir. 2006)

holding that multiple counts of conviction under § 922(g) arising out of a single act of possession of a firearm should be merged at sentencing into a single offense

Summary of this case from United States v. Carnes

holding that separate convictions arising out of a single act under § 922(g) are multiplicitous

Summary of this case from United States v. Harris

holding that "Congress intended the 'allowable unit of prosecution' to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification. . . " and remanding case to district court "to vacate the sentence, merge the counts of conviction [for being a felon in possession of a firearm in violation of § 922(g)(1) and being a drug user in possession of a firearm in violation of § 922(g)(3)] into one count, and resentence the defendant based on a single conviction under 18 U.S.C. § 922(g)."

Summary of this case from McFarlane v. United States

holding that the counts of conviction under Section 922(g) and for a single incident of possession should be merged into one count and defendant should be resentenced based on a "single conviction under 18 U.S.C. §922(g)"

Summary of this case from United States v. Hayes

finding that Congress intended the "allowable unit of prosecution" under section 922(g) to be "an incident of possession"

Summary of this case from United States v. Shipley

finding that separate charges of being a felon in possession of a firearm and being a drug user in possession of a firearm were multiplicitous

Summary of this case from U.S. v. Johnson

reversing its earlier position and joining with nine other circuits in recognizing this rule regarding § 922(g) charges

Summary of this case from U.S. v. Johnson

examining precedent supporting the imposition of one sentence

Summary of this case from United States v. Zareck

In Richardson, there was only one firearm, and the two counts charged the defendant with possessing the firearm on the same date.

Summary of this case from United States v. Woolsey

In United States v. Richardson, 439 F.3d 421, 422 (8th Cir. 2006) (en banc), decided three years before the sentencing in this case, we joined the other circuits that had addressed the issue and held, en banc, that "Congress intended the 'allowable unit of prosecution' to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification."

Summary of this case from U.S. v. Yocum

In United States v. Richardson, 439 F.3d 421 (8th Cir. 2006), the Eighth Circuit held that "Congress intended the allowable unit of prosecution to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification, possessed more than one firearm, or possessed a firearm and ammunition."

Summary of this case from Norris v. United States

In Richardson, the defendant, a drug user and felon, possessed a firearm on February 4, 2003. Richardson, 439 F.3d at 422.

Summary of this case from United States v. Hayes

remanding and ordering the court to "merge the counts of conviction into one count, and resentence the defendant based on a single conviction under 18 U.S.C. § 922(g)"

Summary of this case from U.S. v. Johnson

In United States v. Richardson, 439 F.3d 421, 422 (8th Cir. 2006), the Eighth Circuit Court of Appeals, in discussing firearms prosecutions under 18 U.S.C. § 922, held that "Congress intended the `allowable unit of prosecution' to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification, possessed more than one firearm, or possessed a firearm and ammunition."

Summary of this case from U.S. v. Parsons

In United States v. Richardson, 439 F.3d 421, 422 (8th Cir. 2006), the Eighth Circuit Court of Appeals, in discussing firearms prosecutions under 18 U.S.C. § 922, held that "Congress intended the `allowable unit of prosecution' to be an incident of possession regardless of whether a defendant satisfied more than one § 922(g) classification, possessed more than one firearm, or possessed a firearm and ammunition."

Summary of this case from U.S. v. Smith

In Richardson, the defendant was charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1), and with being a drug user in possession of the same firearm in violation of 18 U.S.C. § 922(g)(3).

Summary of this case from U.S. v. Elizarraras-Sepulveda

In Richardson, the defendant was charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1), and with being a drug user in possession of the same firearm in violation of 18 U.S.C. § 922(g)(3).

Summary of this case from U.S. v. McCall
Case details for

U.S. v. Richardson

Case Details

Full title:United States of America, Appellee, v. Earnest Jesse Richardson, etc.…

Court:United States Court of Appeals, Eighth Circuit

Date published: Mar 2, 2006

Citations

439 F.3d 421 (8th Cir. 2006)

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