United States v. Mendez, No. 13-30170 (9th Cir. 2014)
Annotate this CaseIn 2007, a juvenile court adjudicated Mendez guilty of second-degree unlawful possession of a firearm. If committed by an adult, the offense is a felony punishable by up to five years in prison. In 2012, after Mendez had become an adult, a park ranger found him in possession of a shotgun. Based on the juvenile adjudication, the federal government charged him with violating 18 U.S.C. 922(g)(1), which makes it unlawful for a person to possess a firearm if he
Court Description: Criminal Law. Affirming the district court’s denial of a motion to dismiss a felon-in-possession-of-a-firearm charge under 18 U.S.C. § 922(g)(1), the panel held that under Washington law, the defendant’s juvenile adjudication of second-degree unlawful possession of a firearm in violation of Revised Code of Washington § 9.41.040(2)(a) – an offense that, if committed by an adult, is a felony punishable by up to five years in prison – constitutes a “conviction” of “a crime punishable by imprisonment for a term exceeding one year” and may therefore serve as a predicate for the § 922(g)(1) prosecution. Observing that Washington law treats juvenile adjudications as convictions once a defendant enters the adult criminal justice system, the panel rejected the defendant’s contention that Washington law establishes a general rule barring the treatment of juvenile adjudications as “convictions” of “crimes.”
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