United States v. Freddie Grant, 753 F.3d 480

In 2012 RCSD executed a search warrant at Freddie Grant’s home and found two boxes of ammunition; Grant, a convicted felon, was indicted and a jury convicted him under 18 U.S.C. § 922(g)(1).
A PSR classified Grant as an Armed Career Criminal (ACCA) based on three prior convictions: two general court-martial convictions from 1980 for (1) assault (inflicting grievous bodily harm) and (2) kidnapping, plus a separate federal drug conviction.
The court-martial convictions occurred while Grant was in the Army in Korea; he received a dishonorable discharge and a lengthy military sentence.
The ACCA enhancement raised Grant’s Guidelines range (offense level 33, criminal history category IV), producing a 188–235 month range; the district court sentenced him to 212 months after considering § 3553(a) factors.
Grant appealed, arguing general courts-martial do not qualify as "any court" under the ACCA and thus his military convictions should not serve as ACCA predicates.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether convictions by a general court-martial qualify as prior "convictions by any court referred to in § 922(g)(1)" for purposes of the ACCA	Grant: general courts-martial are materially different from civilian courts (Article I origin, different procedures and composition) and thus should be excluded under the Supreme Court’s reasoning in Small	Gov't: court-martial convictions are valid predicate convictions; including them furthers ACCA’s purpose to target violent habitual offenders and nothing in the statute or scheme excludes courts-martial	The Fourth Circuit affirmed: general court-martial convictions may be counted as ACCA predicates; Small does not require excluding courts-martial from "any court"

Small v. United States, 544 U.S. 385 (2005) (interpreting "any court" in § 922(g)(1) and excluding foreign convictions under extraterritoriality and fairness concerns)
Begay v. United States, 553 U.S. 137 (2008) (explaining ACCA’s focus on offenders whose criminal history indicates special danger when possessing a gun)
O'Callahan v. Parker, 395 U.S. 258 (1969) (discussing differences between military and civilian courts)
Solorio v. United States, 483 U.S. 435 (1987) (addressing the constitutional basis for court-martial jurisdiction)
United States v. Martinez, 122 F.3d 421 (7th Cir. 1997) (holding courts-martial qualify as courts under ACCA)
United States v. MacDonald, 992 F.2d 967 (9th Cir. 1993) (same conclusion regarding courts-martial under § 922(g)(1))
United States v. Lee, 428 F.2d 917 (6th Cir. 1970) (treating courts-martial judgments as final and conclusive like civil-court judgments)
Taylor v. United States, 495 U.S. 575 (1990) (context on the history and purpose of career-offender enhancements)
Grafton v. United States, 206 U.S. 333 (1907) (on the finality and conclusive effect of court-martial judgments)
United States v. Davis, 689 F.3d 349 (4th Cir. 2012) (noting de novo review of legal conclusions regarding ACCA classification)