Questions presented
SCOTUS records, cert granted 8 Jan 2021
Whether a defendant who pleaded guilty to possessing a firearm as a felon, in violation of 18 U.S.C. 922(g)(1) and 924(a), is automatically entitled to plain-error relief if the district court did not advise him that one element of that offense is knowledge of his status as a felon, regardless of whether he can show that the district court’s error affected the outcome of the proceedings.
Opinion summary
Etalia.ai summary of the majority opinion
The case involved a challenge to the validity of guilty pleas entered by individuals who were not informed that they were prohibited from possessing firearms under federal law due to prior felony convictions. The Supreme Court addressed whether such an omission constituted a structural error, which would automatically invalidate the plea without requiring proof of prejudice. The Court held that failing to inform defendants about this specific prohibition did not amount to structural error and thus did not automatically render their guilty pleas invalid. Instead, defendants must demonstrate actual prejudice resulting from the lack of information in order for their pleas to be overturned.
Opinion written by Justice Kavanaugh
Decided 14 Jun 2021 · Official report