Potts v. State

IVAN POTTS v. STATE OF MARYLAND
Court of Special Appeals, Wright, Dec. 28, 2016,
Merger – Where a prohibited person is convicted of possession of a regulated firearm under PS 5-133(c)(1) and possession of ammunition under PS 5-133.1, the sentences do not merge.

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Voisine v. United States

STEPHEN L. VOISINE AND WILLIAM E. ARMSTRONG, III, PETITIONERS v. UNITED STATES
Supreme Court of the United States, Kagan, June 27, 2016,
Firearm Possession – 18 USC 922(g)(9) – A charge based on the reckless form of domestic assault can trigger the ban for those convicted of a “misdemeanor crime of domestic violence.”

(Dissent – Thomas with Sotomayor in part – “using force” suggests a level of intent not found in recklessness)

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