Rehaifv.United States
Hamid Rehaif entered the United States on a nonimmigrant student visa, was dismissed from university after poor grades, and later fired two guns at a firing range. The Government prosecuted him under federal law prohibiting firearm possession by certain categories of people, including aliens unlawfully in the country. The trial court instructed the jury that the Government did not need to prove Rehaif knew he was unlawfully present, and the Eleventh Circuit affirmed. The Supreme Court reversed. It held that the word “knowingly” in the statute applies both to the defendant’s possession of a firearm and to the defendant’s knowledge of the status that makes possession unlawful. The Government therefore had to prove that Rehaif knew he possessed the firearms and knew he belonged to the relevant prohibited category. The Court distinguished ignorance of the law from a mistake about a status element and remanded for further proceedings. Justice Alito, joined by Justice Thomas, dissented and argued that the statute required a narrower mental-state reading.
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