United States v. Minor, No. 20-1903 (1st Cir. 2022)
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The First Circuit vacated Defendant's conviction of knowingly violating 18 U.S.C. 922(g), which prohibits nine categories of persons from possessing a firearm, holding that the trial court erred when it allowed the jurors to convict without finding that Defendant knew his state-court conviction placed him in the relevant category of persons barred from possessing a firearm.
In Rehaif v. United States, 139 S. Ct. 2191 (2019), the Supreme Court held that convictions under section 924(a)(2) for knowingly violating section 922(g) require "the Government [to] prove both that the defendant knew he possessed a firearm and that he knew he belonged to the relevant category of persons barred from possessing a firearm." On appeal in the instant case, Defendant argued that the proceedings were tainted by errors relating to the mens rea requiring to establish a knowing violation fo section 922(g). The First Circuit vacated the conviction, holding that there was harmful error where the jury was allowed to convict Defendant of knowingly violating section 922(g)(9) without finding that he knew that his assault conviction placed him in the category of persons convicted of a misdemeanor crime of domestic violence.
The court issued a subsequent related opinion or order on April 14, 2022.
The court issued a subsequent related opinion or order on March 24, 2023.
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