United States v. Davies, No. 18-2662 (8th Cir. 2019)Annotate this Case
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.