Rehaif v. United States

Summary

The Supreme Court held that, in a prosecution 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 and remanded the Eleventh Circuit’s judgment, leaving the harmless-error question for the lower courts.

Holdings

1. 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 or ammunition.
2. The Government must prove that the defendant knew he belonged to the relevant category of persons barred from possessing a firearm; for Rehaif, that meant proving he knew he was an alien unlawfully present in the United States.
3. The Court decided only the mens rea issue presented concerning the status at issue in Rehaif's prosecution and did not decide precisely what the Government must prove regarding knowledge of status under other § 922(g) provisions.
4. The Supreme Court did not decide whether the erroneous jury instruction was harmless because the lower courts had not addressed harmlessness; that issue was left for consideration 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, in such a prosecution, the Government must prove that the defendant knew he belonged to the category of persons barred from possessing firearms.
3. Whether the jury-instruction error was harmless.

Disposition

reversed_and_remanded