Rehaif v. United States

Summary

The Supreme Court held that, in prosecutions under 18 U.S.C. §§ 922(g) and 924(a)(2), the Government must prove that the defendant knew both that he possessed a firearm and that he belonged to the relevant category of persons barred from possessing firearms. The Court reversed the Eleventh Circuit’s judgment and remanded for further proceedings, including consideration of whether the instructional error was harmless. Justice Alito, joined by Justice Thomas, dissented.

Holdings

1. The Government must prove that the defendant knew both that he possessed a firearm and that he belonged to the relevant category of persons barred from possessing a firearm.
2. The ordinary rule that ignorance of the law is no excuse does not preclude requiring knowledge of a collateral legal matter when ignorance of that matter negates an element of the offense.
3. The Supreme Court did not decide whether the instructional error was harmless; that issue was left for the lower courts on remand.

Questions Presented

1. Whether, in a prosecution under 18 U.S.C. §§ 922(g) and 924(a)(2), the Government must prove that the defendant knew he possessed a firearm.
2. Whether the Government must prove that the defendant knew he belonged to the relevant category of persons barred from possessing a firearm.
3. Whether the instructional error, if any, was harmless.

Disposition

reversed_and_remanded