United States v. Charles Philip MacDonald

KLEINFELD, Circuit Judge:

MacDonald was convicted of various crimes involving unlawful possession and sale of firearms. He appeals on two issues, whether his army court-martial conviction was a sufficient basis for felon in possession under 18 U.S.C. § 922(g)(1), and whether the judge erred in the guidelines calculation of offense level for the gun sales. We affirm.

MacDonald was court-martialed forty years ago for fraudulent enlistment, failure to obey a lawful order, and sale of a “liberty pass,” in violation of the Uniform Code of Military Justice, and sentenced to two years at hard labor.…