United States v. Fidel Mendez

In 2007, a juvenile court adjudicated Fidel Mendez guilty of second-degree unlawful possession of a firearm, in violation of Revised Code of Washington (RCW) § 9.41.040(2)(a). That offense, if committed by an adult, is a felony punishable by up to five years in prison. RCW §§ 9.41.040(2)(b), 9A.20.021(l)(c). In 2012, after Mendez had become an adult, a park ranger found him in possession of a shotgun. The federal government charged him with violating 18 U.S.C. § 922 (g)(1), which makes it unlawful for a person to possess a firearm if he’s previously been “convicted in any court of, a crime punishable by imprisonment for a term exceeding one year.” The indictment alleged— based on the 2007 juvenile adjudication— that Mendez had been convicted of a such a crime.

Mendez moved to dismiss the charge on the ground that, under Washington law, his 2007 juvenile adjudication does not constitute a “conviction” of a “crime” for purposes of § 922(g)(1). After the district court denied the motion, Mendez entered a conditional guilty plea, reserving the right to challenge on appeal whether his 2007 juvenile adjudication meets the statutory definition of “a crime punishable by…