June 3, 2014 4th Circuit published opinion

United States v Grant

Grant was convicted of felon in possession of ammunition. He challenged his designation as an armed career criminal arguing his military convictions are not crimes which could be used to establish his status. The district court rejected his argument and the panel affirmed. It held that general courts martial are “any court” for purposes of the career criminal guidelines. It noted that the united state Supreme Court has held “any court” does not include foreign courts, but, held that courts martial are sufficiently like civilian criminal courts to count the convictions and congressional policy of identifying and deterring career criminals is served by including military convictions.

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