Howling v. StateAnnotate this Case
The Court of Appeals affirmed the judgment of the court of special appeals, which affirmed Defendants' convictions of possessing a firearm, holding that the State provided sufficient evidence to establish that Defendants knew they were prohibited from possessing a firearm.
Defendants Mashour Howling and Funiba Abangnelah each possessed a firearm at the time of arrest despite being disqualified to do so. In separate jury trials, both Defendants unsuccessfully requested that the respective circuit courts give a jury instruction incorporating the reasoning of Rehaif v. United States, 139 S. Ct. 2191 (2019), where the United States Supreme Court held that the federal statute required proof of knowledge of possession of a firearm and proof of knowledge of the defendant's status as a person prohibited from possessing a firearm. After Defendants were convicted the court of special appeals affirmed. The Court of Appeals affirmed, holding that the the circuit court did not abuse its discretion in declining to give Defendants' requested jury instructions.