CASE ANALYSIS

United States v. First, 731 F.3d 998 (9th Cir. 2013).

In United States v. First,  the Ninth Circuit Court of Appeals reversed the United States District Court for the District of Montana's dismissal of the government's indictment of Lakota Thomas First for misdemeanor firearms possession.   The Ninth Circuit held that misdemeanor convictions obtained in tribal courts may qualify as predicate offenses to a prosecution under 18 U.S.C.

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