United States v. Bryant, No. 18-3569 (2d Cir. 2020)
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The Second Circuit affirmed defendant's conviction and sentence for conspiring to distribute cocaine base and possession of a firearm as a convicted felon, but vacated two challenged conditions of supervised release and remanded in part.
The court held that defendant's guilty plea to possessing a firearm as a convicted felon remains valid, even in light of Rehaif v. United States, 139 S. Ct. 2191 (2019), because it is plain that defendant knew of his unlawful status when he possessed the firearm and there is no reasonable probability that he would have not pled guilty had he been properly informed that such knowledge was a requirement for conviction under 18 U.S.C. 922(g). The court also held that there was no error at sentencing in the district court's consideration of potential sentencing disparities among similarly situated defendants, and defendant's 90-month sentence was not procedurally or substantively unreasonable. Finally, the court held that the two disputed conditions of supervised release imposed on defendant are not unconstitutionally vague, but the court remanded (1) the risk condition so that the district court can formally incorporate its oral amendment of that condition into the written judgment of conviction, and (2) the communication condition so that the district court may provide the necessary justification for restricting defendant's communications with his brother, or exempt such communications from that condition.
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