United States v. Turner, No. 16-1142 (8th Cir. 2016)
Annotate this CaseDefendant pled guilty to one count of possession of a firearm and ammunition by an unlawful drug user in violation of 18 U.S.C. 922(g)(3) and 924(a)(2). On appeal, defendant challenged the denial of his motion to dismiss because 18 U.S.C. 922(g)(3) was unconstitutionally vague as applied to the facts of his case. The court concluded that a trial on the merits was needed to decide defendant's pretrial motion to dismiss where the parties dispute what evidence the district court could consider in its ruling. In this case, the district court could not rule on defendant's as applied constitutional challenge without resolving factual issues related to his alleged offense, such as the extent of his drug use, and therefore the district court should have deferred ruling until trial. The court concluded that this premature ruling prejudiced defendant's ability to obtain appellate review of his constitutional challenge, for he conditionally pled guilty under his mistaken assumption that he could "have an appellate court review an adverse determination" of his motion to dismiss. The court explained that had the district court informed defendant that it would have to defer a final ruling on his motion, defendant could have moved to vacate his guilty plea and proceeded to trial on the original charges. Accordingly, the court reversed and remanded.
Court Description: Murphy, Author, with Benton and Shepherd, Circuit Judges] Criminal case - Criminal law and sentencing. The district court could not rule on Turner's claim that 18 U.S.C. Sec. 922(g)(3) was unconstitutional as applied without resolving the factual issues related to his alleged offense, such as the extent of his drug use, and the court should have deferred ruling on the motion to dismiss until after trial; by prematurely ruling on the motion, the district court prejudiced Turner's ability to obtain appellate review of the challenged, for he conditionally pled guilty under the mistaken assumption that he could have an appellate review of the adverse determination of his motion; however, he could not both plead guilty and obtain appellate review of his constitutional challenge; had the court informed Turner that it would have to defer a final ruling on his motion, Turner could have moved to vacate his guilty plea and proceeded to trial; remanded to permit Turner to consider this choice.
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