USA v. Ahmadou
Split Score
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Case Summary
Disposition
Affirmed
The Fifth Circuit rejected Moctar Ahmadou Gouroudja Ahmadou’s appeal from his conviction for possessing a firearm while on a non-immigrant visa, holding that he was not entitled to an entrapment-by-estoppel defense, that the district court properly denied an acceptance-of-responsibility reduction, and that the above-Guidelines sentence was reasonable. In doing so, the court explicitly sided with the Seventh, Eighth, Tenth, and Eleventh Circuits against the Ninth Circuit on whether a federally licensed firearms dealer qualifies as a federal official for purposes of the entrapment-by-estoppel defense, thereby affirming the judgment in full.
Circuit Split Identified
Legal Issue
Whether a federally licensed firearms dealer is a federal official/agent whose statements can trigger the entrapment-by-estoppel defense under Raley v. Ohio and Cox v. Louisiana.
Circuit Positions
Federally licensed firearms dealer IS a federal official for purposes of entrapment-by-estoppel.
Federally licensed firearms dealer IS NOT a federal official for purposes of entrapment-by-estoppel.
Conflict Summary
The Ninth Circuit treats licensed firearms dealers as federal officials, allowing defendants to invoke the entrapment-by-estoppel defense when they reasonably rely on a dealer’s misstatement of the law. The Fifth, Seventh, Eighth, Tenth, and Eleventh Circuits conclude that licensed dealers are private actors, not government officials, so their representations cannot estop the government from prosecuting firearm offenses.