United States v. Jones, No. 19-1768 (7th Cir. 2020)
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In trials before the Supreme Court’s 2019 “Rehaif” decision, three defendants were separately convicted under 18 U.S.C. 922(g), which prohibits convicted felons and several other classes of people from possessing firearms or ammunition. Before Rehaif, federal courts held that section 922(g) required the government to prove a defendant knowingly possessed a firearm or ammunition, but not that the defendant knew he belonged to one of the prohibited classes. In Rehaif, the Supreme Court held that the statute requires the government to “show that the defendant knew he possessed a firearm and also that he knew he had the relevant status when he possessed it.” On appeal, the defendants asserted a missing element in their indictments and jury instructions and a denied motion for a judgment of acquittal.
Employing plain‐error review, the Seventh Circuit affirmed two sentences but vacated the third, based on a “Tapia error,” imposing a longer prison term for purposes of rehabilitation through prison programs. Rehaif does not impose a willfulness requirement on section 922(g) prosecutions. The court noted the important difference between requiring knowledge of status and knowledge of the criminal prohibition and reasoned that the Supreme Court would not have adopted the broader reading without saying so with unmistakable clarity. The court noted that none of the defendants objected to his indictment or his jury instructions and concluded that none of them were prejudiced by the omission of a reference to knowledge of his status.
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