United States v. Guzman-Merced, No. 18-2146 (1st Cir. 2020)
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The First Circuit vacated Defendant's plea of guilty to one count of violating 18 U.S.C. 922(g)(1), which makes it a crime for a convicted felon to possess a firearm, holding that there was a reasonable probability that Defendant would not have pled guilty had he been advised that the government need prove that he knew when he possessed the gun that he was a felon.
Defendant pleaded guilty in 2018 to one count of violating section 922(g)(1). In 2019, the United States Supreme Court held in Rehaif v. United States, 139 S. Ct. 2191, 2200 (2019), that a conviction for that crime requires proof beyond a reasonable doubt that when the defendant possessed the gun he knew he had previously been convicted of an offense punishable by more than one year in prison. The First Circuit vacated Defendant's conviction, holding (1) the district court's failure to advise Defendant of Rehaif's knowledge requirement was clear error; and (2) there was a reasonable probability that Defendant would not have pled guilty had he been informed in accordance with Rehaif.
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