US v. Medley: Medley was convicted at trial in 2017 with being a felon in possession of a firearm. While his appeal was pending, the Supreme Court decided Rehaif, which held that to prove that offense the Government must show not only that the defendant was of a certain restricted status, but that the defendant was aware of that fact. In supplemental briefing, Medley argued that after Rehaif his conviction had to be reversed because the status knowledge element was neither pled in the indictment or part of the jury’s instructions, leading to a conviction on insufficient evidence.
A divided Fourth Circuit agreed and reversed Medley’s conviction, applying plain error review. There was no dispute that there was Rehaif error and that error was plain. The dispute was over whether that error impacted Medley’s substantial rights and whether the court should notice it and reverse his conviction. Examining each error individually, the court concluded that each of them impacted Medley’s substantial rights, as did the weight of the errors together. As to whether to notice the error, the court concluded that regardless of whether they individually required notice, the combined errors were “sufficient to undermine confidence in the outcome of the proceedings.”
Judge Quattlebaum dissented, arguing that if “ever there was a case in which errors likely had no effect on the outcome of the proceedings, and the proceedings led to a fair and reliable determination of guilt, this is it,” noting that (among other things) Medley “remained on parole” at the time of his offense.
Congrats to the Defender office in Maryland on the win!
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