United States v. Davies, No. 18-2662 (8th Cir. 2019)
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After defendant pleaded guilty to two Iowa felonies in September 2016, but before his sentencing, he possessed two firearms. A grand jury returned an indictment charging defendant with being a felon in possession of a firearm. The district court determined that defendant's guilty plea constituted a conviction under Iowa law and found him guilty of being a felon in possession of a firearm.
The Eighth Circuit agreed with the district court's conclusion that defendant's guilty pleas constituted convictions under Iowa law. Under Rehaif v. United States, 139 S. Ct. 2191 (2019), the court held that the Government did not prove that defendant knew he had been convicted of a felony at the time he possessed the firearms. Therefore, in light of Rehaif, the court vacated defendant's conviction and remanded for a new trial.
Court Description: Gruender, Author, with Benton and Shepherd, Circuit Judges] Criminal case - Criminal law. Defendant's guilty pleas constituted convictions under Iowa law and he was a felon at the time he possessed the firearm; the government failed to prove defendant knew he had been convicted at the time he possessed the firearm; as a result, Rehaif requires that his conviction be vacated and that the matter be remanded for a new trial.
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