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Phillips v. United States — Court Affirms Convictions but Remands Sentence Over Missing Prior-Conviction Inquiry

The DC Court of Appeals affirmed Bryant Phillips’s convictions for sexual abuse, kidnapping, and assault but remanded for resentencing, holding that the trial court failed to conduct the mandatory statutory inquiry under D.C. Code § 23-111(b) before imposing a life-without-parole sentence as a repeat violent offender.