Until the recent decision in United States v. Richardson, the Eighth Circuit was the only circuit in the United States to permit multiple convictions for single acts of possessing a firearm or ammunition. This Note will explore the rationale and the ramifications of this decision and illustrate that, while it took the Eighth Circuit longer than it should have, this shift represents a step toward the realization of a more just and satisfactory criminal justice system, where convictions are based not on conjecture and speculation, but on practical interpretations of legislative intent.
Multiple Convictions for Single Acts of Possession - The Eighth Circuit Finally Gets It Right,
72 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol72/iss1/12