Rehaif v. United States, 139 S. Ct. 2191

Petitioner Hamid Rehaif entered the U.S. on a nonimmigrant student visa, lost his enrollment, remained in the country, and later fired firearms at a range.
He was charged under 18 U.S.C. §922(g) (possession by certain categories, including aliens "illegally or unlawfully in the United States") and §924(a)(2) (whoever "knowingly violates" §922(g)).
At trial the jury was instructed the Government need not prove Rehaif knew his immigration status was unlawful; he was convicted and sentenced to 18 months.
The Eleventh Circuit affirmed, applying the then-uniform circuit rule that §922(g) does not require proof the defendant knew his disqualifying status.
Supreme Court granted certiorari to decide whether the Government must prove the defendant knew both that he possessed a firearm and that he belonged to the status-based category barred from possession.

Issue	Rehaif's Argument	Government's Argument	Held
Whether §924(a)(2)’s "knowingly" requires proof of knowledge of status in a §922(g) prosecution	"Knowingly" applies to all elements of §922(g); Gov must prove defendant knew he was an alien unlawfully in the U.S.	Statutes commonly do not require defendants to know their own status; "ignorance of law" bars defense; long circuit practice supports no status knowledge requirement	The Government must prove the defendant knew he possessed a firearm and knew he belonged to the relevant status-based category (knowledge of status required)

United States v. X-Citement Video, 513 U.S. 64 (1994) (presumption in favor of scienter applies to elements criminalizing otherwise innocent conduct)
Flores-Figueroa v. United States, 556 U.S. 646 (2009) ("knowingly" ordinarily applies to subsequently listed elements)
Staples v. United States, 511 U.S. 600 (1994) (presumption of scienter and when to require it)
Morissette v. United States, 342 U.S. 246 (1952) (importance of mens rea in criminal law)
Liparota v. United States, 471 U.S. 419 (1985) (knowledge required as to legal significance of collateral matter can be required)
Old Chief v. United States, 519 U.S. 172 (1997) (evidentiary implications of proving prior-conviction status)
United States v. Feola, 420 U.S. 671 (1975) (knowledge-of-status not required for jurisdictional/victim-status elements in certain federal crimes)
Bousley v. United States, 523 U.S. 614 (1998) (actual-innocence gateway to collateral relief)
Cheek v. United States, 498 U.S. 192 (1991) (distinction between mistake of law and mistake about collateral legal consequences)