In U.S. v. Santiago, No. 09-10466 (April 2, 2010), the Court held that a guilty plea followed by a sentence of probation and a withholding of adjudication under Florida law qualified as a prior “conviction” for purposes of enhancing an offender’s sentence under 18 U.S.C. § 922(g)(1).
Rejecting the defendant’s interpretation of the statute, the Court noted that the determination whether a prior judgment should be treated as a “conviction” was a matter of State law. Here, Florida’s habitual offender law expressly provided that a sentence of probation without an adjudication of guilty “shall be treated as a prior conviction.” Thus, Santiago’s prior judgment, along with two other prior convictions, qualified him for the enhanced sentence.