United States v. Gauld, No. 15-1690 (8th Cir. 2017)Annotate this Case
The Eighth Circuit granted en banc review and held that a state juvenile delinquency adjudication is a "prior conviction" under 18 U.S.C. 2252(b)(1). The en banc court held that, because federal law distinguishes between criminal convictions and juvenile delinquency adjudications, and because section 2252(b)(1) mentions only convictions, juvenile delinquency adjudications do not trigger that statute's 15-year mandatory minimum sentence. Accordingly, the en banc court vacated defendant's sentence and remanded for resentencing.
This opinion or order relates to an opinion or order originally issued on August 18, 2016.