United States v. Caudle, No. 19-3219 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to being a felon in possession of a firearm in violation of 18 U.S.C. 922(g)(1). The court held that the undisputed facts taken together establish a nexus between defendant and his wife sufficient to support the district court's finding of constructive possession. In this case, the couple's joint occupancy of the home and joint possession of the three firearms support an inference that defendant had knowledge of, and access to the pistol found in his wife's vehicle.
The court also held that there was no plain Rehaif error that warrants giving defendant another opportunity to withdraw the guilty plea that he did not seek to withdraw at sentencing. The court explained that defendant has not shown a reasonable probability that he would not have pleaded guilty had he known of Rehaif.