United States v. Reynoso, No. 19-3045 (D.C. Cir. 2022)
Annotate this CaseDefendant-appellant Manuel Reynoso was convicted by jury on a gun-possession charge and two drug charges. On appeal, Reynoso challenged his convictions on several grounds. On the same day the district court sentenced Reynoso, the U.S. Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), which established that the felon-in-possession statute required the government to show not only that the defendant knew he possessed a gun but also that he knew he had previously been convicted of a crime punishable by more than a year of imprisonment. Reynoso contended on appeal that his felon-in-possession conviction had to be overturned due to the government’s failure to make the additional showing Rehaif required. Because Reynoso did not raise that argument in the district court, the Circuit Court of Appeals for the District of Columbia reviewed his claim for only plain error. After the appellate court heard oral argument in this case, the Supreme Court granted review in another case to consider whether a person might be entitled to plain-error relief on appeal in a case involving a Rehaif error, Greer v. United States, 141 S. Ct. 2090 (2021). Greer held that Rehaif errors at trial normally will not qualify as plain errors of a kind warranting relief in appeals from felon-in-possession convictions. In accordance with Greer, the Court of Appeal concluded the district court’s Rehaif error in this case did not amount to plain error. The Court also rejected Reynoso’s other challenges to his convictions, thus affirming the district court.
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