Supreme Court of the United States
Hamid Mohamed Ahmed Ali Rehaif, Petitioner v. United States
June 21, 2019588 U.S. 225
Summary
The Supreme Court held that in a prosecution under 18 U.S.C. § 922(g) and § 924(a)(2) the word 'knowingly' applies to both the conduct and the status elements, so the Government must prove that the defendant knew he possessed a firearm and also knew he belonged to the relevant category of persons barred from possessing one. Applying the longstanding presumption in favor of scienter, the Court found that the statutory text, the purposes of criminal law, and Congress's 1986 addition of 'knowingly' all supported requiring knowledge of status, and it rejected the Government's ignorance-of-the-law, reenactment-canon, and legislative-history arguments. It reversed the Eleventh Circuit and remanded, leaving the harmless-error question for the lower courts because they had not addressed it. Justice Alito, joined by Justice Thomas, dissenting, would have held that the statutory text does not compel knowledge of status and that the long-established contrary interpretation adopted by every court of appeals should stand.
Holding
- Whether 'knowingly' in 18 U.S.C. § 924(a)(2) applies to both the conduct element (possession of a firearm) and the status element (e.g., being an alien illegally or unlawfully in the United States) of a § 922(g) offense.. The word 'knowingly' applies both to the defendant's conduct and to the defendant's status; to convict, the Government must show that the defendant knew he possessed a firearm and also that he knew he had the relevant status when he possessed it.
Docket 17-9560
Cited authorities
- CA10
- 8 U.S.C. 1101(a)(26)
- CA11
- CA10
- CA10
- CA10
- CA11
- 52 Stat. 1250