Brummer: Firearm forfeiture Mandatory

In U.S. v. Brummer, No. 09-13613 (March 8, 2010), the Court held that forfeiture of firearms or ammunition is mandatory for defendants convicted of knowingly and willfully failing to declare firearms to a common carrier, in violation of 18 U.S.C. § 922(e). The Court relied on the plain language of the statute, specifically its use of the word “shall” with reference to the order of forfeiture.