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Seabrooksv.United States

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.20-13459
DecidedMay 6, 2022
Reporter32 F.4th 1375
JudgesCircuit Judges Wilson and Rosenbaum and District Judge Anne C. Conway, sitting by designation
Tags
CriminalCriminal ProcedurePost-Conviction ReliefStatutory InterpretationJury InstructionsVacaturReversalRemand
Case Summary

Seabrooks was convicted of possessing a firearm as a felon after riding with Butler, who stole guns from a truck; the jury could convict on actual possession or aiding and abetting. Seabrooks admitted briefly handling one gun but denied joining the theft. The aiding-and-abetting instruction did not require proof that he knew Butler was a felon, as Rehaif later required. On Seabrooks’s initial § 2255 motion, the Eleventh Circuit held that Rehaif applied retroactively and the claim was neither procedurally barred nor defaulted. The error was not harmless: the prosecution urged aiding and abetting as an alternative, the jury asked whether touching a gun amounted to possession, and its general verdict did not identify its theory. The Court reversed denial of the motion, vacated the felon-in-possession conviction, and remanded.

Opinion

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