Supreme Court of the United States · 2019 · Criminal Law
588 U.S. 225 (2019)
Updated
Criminal Lawmens reaknowledge of statusscienterknowledgestatus elementfirearm possession18 U.S.C. 922(g)
Facts
Hamid Rehaif entered the United States on a nonimmigrant student visa to attend university. After the university dismissed him for poor grades, it told him that his immigration status would be terminated unless he transferred schools or left the country, but he did neither. He later went to a firing range and shot two firearms. The Government prosecuted him under §§ 922(g) and 924(a)(2), and the trial court instructed the jury that the Government did not need to prove he knew he was illegally or unlawfully in the United States.
Issue
In a prosecution under 18 U.S.C. §§ 922(g) and 924(a)(2), must the Government prove that the defendant knew not only that he possessed a firearm, but also that he belonged to the relevant category of persons barred from possessing a firearm?
Rule
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 and also knew he had the relevant prohibited status when he possessed it. The scienter requirement does not apply to the statute's jurisdictional element.
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Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, Mateo Ruiz bought a handgun at a pawn shop and kept it in his apartment. Federal prosecutors charged him under 18 U.S.C. §§ 922(g) and 924(a)(2) as a person in a prohibited category, proving he in fact fell within that category but offering no evidence that he knew he did when he possessed the gun.
What is the strongest argument for acquittal?
Explanation. Under the majority opinion, in a prosecution under §§ 922(g) and 924(a)(2), the government must prove the defendant knew he possessed a firearm and knew he had the relevant prohibited status at the time of possession. The Court rejected the view that status is strict liability, but it did not require proof that the defendant knew his conduct was illegal.