Term: 2020
Docket: 19-8709
Greer v. United States
- Pro
19-8709 GREER V. UNITED STATES DECISION BELOW: 798 F.Appx 483 CERT. GRANTED 1/8/2021 QUESTION PRESENTED: Last year, this Court held in Rehaif v. United States, 139 S. Ct. 2191 (2019), that, in a prosecution under 18 U.S.C. §§ 922(g) and 924(a)(2), the government must prove not only that the defendant knew he possessed a firearm, but also that he knew he belonged to the relevant category of persons barred from possessing a firearm. Since then the circuit courts of appeals have attempted to define the scope of review when applying the holding of Rehaif to cases remanded by this Court. The question presented is: Whether when applying plain-error review based upon an intervening United States Supreme Court decision, a circuit court of appeals may review matters outside the trial record to determine whether the error affected a defendant’s substantial rights or impacted the fairness, integrity, or public reputation of the trial? LOWER COURT CASE NUMBER: 18-12963
In the case of Greer v. United States, 2020, Quintin Greer appealed his conviction for being a felon in possession of a firearm under federal law. He argued that the court had not adequately established that he knew he was legally barred from owning guns due to his criminal history at the time of his offense. The Supreme Court ruled against him by affirming lower courts' decisions and holding that while knowledge is an essential element in proving this type of crime, it does not necessarily need to include awareness about one's prohibited status as a felon. Instead, prosecutors only need to show that defendants knowingly possessed firearms.
In the dissenting opinion for Greer v. United States, Justice Sotomayor argued that the majority's decision to uphold Greer's conviction under the Armed Career Criminal Act (ACCA) was flawed because it did not adequately consider whether he knew he was a felon at the time of his offense. She contended that knowledge of one’s status as a felon is an essential element of being guilty under ACCA and should have been proven beyond reasonable doubt. The majority held that this requirement could be satisfied by simply showing that Greer had previously been convicted of a felony, but Sotomayor disagreed, arguing this approach undermines defendants' rights and contradicts precedent requiring each element of an offense to be proven individually. Furthermore, she expressed concern about potential unfairness in future cases if courts are allowed to presume knowledge based on prior convictions without direct evidence.
