United States v. Austin, No. 19-2257 (1st Cir. 2021)
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The First Circuit denied Defendant's appeal of his conviction for unlawful possession of a firearm by a prohibited person in violation of 18 U.S.C. 922(g) and 924(a)(2), holding that the district court did not commit plain error by accepting Defendant's guilty plea and in denying his motion to suppress.
Following Defendant's plea, the Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), under which the government must prove that the defendant knew he had the relevant status prohibiting possession. On appeal, Defendant argued (1) under Rehaif, the district court committed plain error during his plea colloquy by failing to inform him that the government was required to prove that he knew he was prohibited from possessing firearms; and (2) the district court erred by denying his motion to suppress. The First Circuit affirmed, holding (1) the search warrant issued for Defendant's residence was supported by probable cause; and (2) the district court did not plainly err by accepting Defendant's guilty plea.
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