Mata v. United States, 969 F.3d 91

Petitioner Jose Luis Mata pleaded guilty and was convicted in 2014 of Hobbs Act conspiracy and being a felon in possession of a firearm (18 U.S.C. § 922(g)); he was sentenced to 360 months imprisonment.
Mata’s direct appeal was affirmed. He filed a first § 2255 motion in 2016, which was denied; a subsequent reconsideration request and certificate of appealability were denied.
Mata sought leave from the Second Circuit to file a second or successive § 2255 motion, asserting (1) that Rehaif v. United States requires vacatur of his § 922(g) conviction, and (2) ineffective assistance of counsel based on newly discovered evidence.
Rehaif clarified the mens rea for § 922(g): the government must prove the defendant knew he possessed a firearm and knew he belonged to the class barred from possession—an interpretation of the statute.
The Second Circuit held Mata failed to make the prima facie showing required to authorize a second or successive § 2255: Rehaif is statutory interpretation, not a new rule of constitutional law under § 2255(h)(2), and Mata did not identify or justify newly discovered evidence satisfying § 2255(h)(1).

Issue	Mata's Argument	Government's Argument	Held
Whether Rehaif announced a new rule of constitutional law warranting authorization under 28 U.S.C. § 2255(h)(2)	Rehaif announced a new constitutional rule that negates an element of his § 922(g) conviction	Rehaif was statutory interpretation, not a new constitutional rule; it cannot be the basis for a second/successive § 2255	Denied — Rehaif did not announce a new rule of constitutional law for § 2255(h)(2) purposes
Whether Mata’s ineffective-assistance claim rests on newly discovered evidence meeting § 2255(h)(1) gatekeeping	Mata asserts newly discovered evidence about counsel’s performance justifies a successive § 2255 filing	Mata failed to identify the new evidence, show due diligence, or that evidence would clear his guilt beyond a reasonable doubt	Denied — Mata did not satisfy § 2255(h)(1) requirements; plea colloquy presumption of verity remains controlling

Rehaif v. United States, 139 S. Ct. 2191 (2019) (held government must prove defendant knew both firearm possession and prohibited status under § 922(g); court construed statute)
Massey v. United States, 895 F.3d 248 (2d Cir. 2018) (interpreting a statute does not necessarily announce a new rule of constitutional law)
Washington v. United States, 868 F.3d 64 (2d Cir. 2017) (denying successive relief where Supreme Court decision interpreted a statute, not the Constitution)
In re Price, 964 F.3d 1045 (11th Cir. 2020) (Rehaif did not announce a new rule of constitutional law)
In re Sampson, 954 F.3d 159 (3d Cir. 2020) (per curiam) (Rehaif did not state a new rule of constitutional law)
United States v. Class, 930 F.3d 460 (D.C. Cir. 2019) (Rehaif resolved statutory questions and did not implicate due process)
Herrera-Gomez v. United States, 755 F.3d 142 (2d Cir. 2014) (requirements for newly discovered evidence and due diligence under § 2255(h)(1))
Blackledge v. Allison, 431 U.S. 63 (1977) (strong presumption of verity for admissions at plea hearings)