United States v. Hill, No. 19-3508 (3d Cir. 2024)
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The case involves Carlos Hill, who was convicted in 2013 for possession of a firearm in violation of 18 U.S.C. § 922(g)(1), a law that makes it illegal for a person convicted of a crime punishable by more than a year in prison to possess a firearm. In 2019, Hill sought to challenge his conviction following the Supreme Court's decision in Rehaif v. United States, which overturned previous interpretations of § 922(g)(1) and held that the government must prove that the person knew they belonged to the prohibited group. Hill requested the appointment of counsel to pursue his Rehaif claim in a motion under 28 U.S.C. § 2255. The District Court denied his request, ruling that Hill's § 2255 motion was second or successive and that he did not qualify for relief under Rehaif.
The United States Court of Appeals for the Third Circuit disagreed with the District Court's ruling. The appellate court determined that Hill's § 2255 motion was not second or successive, and that Rehaif announced a new substantive rule that is retroactive for non-successive § 2255 motions. The court concluded that the District Court's order was incorrect and vacated it, remanding the case for further proceedings. The appellate court also issued a certificate of appealability for Hill's appeal, finding that jurists of reason would find it debatable whether Hill has stated a valid constitutional claim and whether the District Court was correct in its procedural ruling.
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