United States v. Grant, No. 19-3824 (6th Cir. 2020)Annotate this Case
Federal prisoner Grant was detained at the Northeast Ohio Correctional Center NEOCC while awaiting sentencing for armed robbery. NEOCC, a privately owned and operated prison, contracts with the U.S. Marshals Service to house federal detainees before trial and/or sentencing. Grant punched a prison guard and ultimately pleaded guilty under 18 U.S.C. 111, which criminalizes assaulting federal officers and those who assist them. Grant contends that section 111 does not apply because the assault victim was a private contractor, not a federal employee, and, at the time of the assault, the contractor was not assisting a federal employee.
The Sixth Circuit affirmed his conviction. Section 111 encompasses circumstances where a private employee performs the same federal duties a federal employee would otherwise fulfill.