USA v. Joshua Eugene Gaines
Split Score
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Case Summary
Disposition
Vacated
The Eleventh Circuit vacated Joshua Gaines’s felon-in-possession conviction, holding that § 922(g)(1) does not reach his Alabama Class D felony because, given Alabama’s sentencing scheme, he could not have been imprisoned for more than one year. The court adopted a defendant-specific reading of § 922(g)(1) and concluded that "imprisonment" means actual jail or prison time, not community-corrections or suspended sentences.
Circuit Split Identified
Legal Issue
Whether 18 U.S.C. § 922(g)(1) is interpreted in an offense-specific manner (looking to the statutory maximum for the predicate crime) or in a defendant-specific manner (looking to the maximum imprisonment actually available to the particular defendant).
Circuit Positions
Defendant-specific reading of § 922(g)(1); crime counts only if THIS defendant could have been sentenced to >1 year of imprisonment.
Offense-specific reading of § 922(g)(1); crime counts if the statute authorizes >1 year regardless of the defendant’s own exposure.
Conflict Summary
Most circuits now apply a defendant-specific approach under Carachuri-Rosendo and Moncrieffe, examining the imprisonment exposure the defendant himself faced; the D.C. Circuit continues to apply an offense-specific approach, looking only to the statute’s abstract maximum.