United States v. Collins, No. 19-4596 (4th Cir. 2020)
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Defendant was convicted of making false statements on an ATF form (Count One) and possessing a firearm after being "adjudicated as a mental defective" (Count Two). On appeal, defendant challenged his firearms conviction, arguing that Rehaif v. United States, 139 S. Ct. 2191 (2019), renders the indictment and jury instructions deficient, that the conviction runs afoul of the Second Amendment, and that the district court imposed an unreasonable sentence.
The Fourth Circuit affirmed the conviction, holding that because defendant had notice of the allegations against him and has not demonstrated that the outcome of the proceedings would have been different without the indictment error, his challenge to the indictment cannot survive plain-error review. The court also held that the jury found, beyond a reasonable doubt, that defendant was guilty of Count One. In doing so, it necessarily found that defendant knew he had been committed to a mental institution, satisfying Rehaif's knowledge-of-status element in Count Two. The court rejected defendant's Second Amendment claim where United States v. Midgett, 198 F.3d 143 (4th Cir. 1999), foreclosed his argument that his commitment under W. Va. Code 27-6A-3(f) does not fall within the realm of ordinary 18 U.S.C. 922(g)(4) challenges because a different West Virginia statute, W. Va. Code 27-5-1 to -11, governs "final commitment proceedings." Rather, defendant's commitment to restore him to competency under W. Va. Code 27-6A-3(f) falls squarely within the definition of committed as used in section 922(g)(4). Finally, the court held that defendant's sentence was procedurally and substantively reasonable.
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