United States v. Leonard, No. 19-14142 (11th Cir. 2021)
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The Eleventh Circuit affirmed defendant's conviction for being a felon in possession of a firearm. On appeal, defendant contends that his indictment was defective for two reasons: it failed to charge a complete criminal offense and it did not inform him that he needed to know his status as a convicted felon.
The court rejected defendant's Rehaif-based contentions and held that the indictment did enough to charge an offense against the United States where 18 U.S.C. 922(g) is by itself a criminal offense. The court also held that an indictment that does not clearly set out the knowledge element does not warrant an automatic presumption of prejudice to the defendant. The court explained that this kind of error is not the sort of structural infirmity that infects the entire trial, and thus the court reviewed it using the same harmless-error inquiry that applies to most other types of errors, including constitutional ones. In this case, any potential error in the indictment was harmless to defendant. Furthermore, the court found no other errors in the conviction or sentence regarding the district court's denial of defendant's motion to reopen, the veracity of the search warrant affidavit, any alleged cumulative error, and defendant's sentence as an armed career criminal.
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