United States v. Richard Shaffer
807 F.3d 943
8th Cir.2015Background
- In 2014 Shaffer pled guilty to bank robbery under 18 U.S.C. § 2113(a) and faced a 20-year statutory maximum.
- The government sought a life sentence under the federal three‑strikes provision, 18 U.S.C. § 3559(c), which mandates life for a federal conviction after two prior "serious violent felonies" in "a court of the United States or of a State."
- Shaffer had a 1979 general court‑martial conviction for unpremeditated murder (served 18 years) and a 2004 federal conviction for multiple bank robberies; both parties agreed these were "serious violent felonies."
- The district court treated the 1979 court‑martial as a conviction in "a court of the United States" and imposed a mandatory life sentence under § 3559(c).
- On appeal Shaffer argued a court‑martial is not a "court of the United States" (he contended the term requires Article III status), so his court‑martial conviction could not serve as a predicate.
- The Eighth Circuit reviewed the statutory interpretation de novo and affirmed, holding courts‑martial fall within § 3559(c)’s phrase "a court of the United States."
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a conviction by court‑martial qualifies as a conviction "in a court of the United States" under 18 U.S.C. § 3559(c) | Shaffer: "court of the United States" is a term of art meaning Article III courts only; courts‑martial are excluded | Government: phrase is expansive; courts‑martial are created by Congress, governed by federal statute, and connected to U.S. government; should be included | Court held courts‑martial are included; Shaffer’s court‑martial counts as a prior qualifying conviction for § 3559(c) |
Key Cases Cited
- United States v. Turley, 352 U.S. 407 (term of art presumption when common‑law meaning fits)
- Johnson v. United States, 559 U.S. 133 (context controls whether statutory phrase is a term of art)
- United States v. Williams, 136 F.3d 547 (8th Cir. standard for de novo statutory interpretation)
- Grafton v. United States, 206 U.S. 333 (court‑martial conviction can bar successive federal prosecution; ties courts‑martial to federal authority)
- United States v. MacDonald, 992 F.2d 967 (9th Cir.) (held court‑martial convictions count in similar federal recidivist context)
- United States v. Martinez, 122 F.3d 421 (7th Cir.) (same conclusion regarding inclusion of courts‑martial)
- United States v. Grant, 753 F.3d 480 (4th Cir.) (held courts‑martial included in ACCA phrase "any court" and discussed statutory purpose)