United States v. Christopher Davies, 942 F.3d 871

In September 2016 Christopher Davies pleaded guilty to two Iowa felonies.
On October 25, after his pleas but before sentencing, Davies possessed two firearms; a federal grand jury indicted him under 18 U.S.C. § 922(g)(1) for being a felon in possession.
At a bench trial the parties stipulated Davies knowingly possessed the firearms; the contested issue was whether his guilty pleas already amounted to "convictions" under Iowa law at the time of the October 25 possession.
In December the Iowa court entered a deferred judgment and placed Davies on probation; the district court concluded the guilty pleas were convictions under Iowa law, convicted Davies of § 922(g)(1), and sentenced him to 37 months.
On appeal Davies argued he was not a convicted felon at the time of possession; he later raised a Rehaif challenge (that the government must prove he knew his felon status). The court ordered supplemental briefing and addressed both issues on de novo review and plain‑error analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a guilty plea followed by a deferred judgment (before sentencing) constitutes a "conviction" under Iowa law for § 922(g)(1) purposes	Davies: No—because sentencing had not occurred and the judgment was deferred	Government: Yes—under Iowa precedent a guilty plea accepted with factual basis and voluntariness is a conviction for felon‑possession purposes	Held: Yes—the Iowa Supreme Court decisions (Deng Kon Tong and Olsen) treat such pleas/judicial findings of guilt as convictions under Iowa law
Whether the government proved, as required by Rehaif, that Davies knew he belonged to the prohibited category (i.e., that he had been convicted), and whether omission of such an instruction was plain error affecting substantial rights	Davies: The govt failed to prove he knew he was convicted on Oct 25; without that proof Rehaif requires reversal	Government: Davies knew he pled to felonies (colloquy, stipulation); govt conceded plain error but argued no effect on substantial rights	Held: The omission was plain error that affected substantial rights and the fairness/integrity of the proceedings; conviction vacated and case remanded for a new trial (retrial not barred by double jeopardy)

Rehaif v. United States, 139 S. Ct. 2191 (2019) (government must prove defendant knew he belonged to the prohibited category in § 922(g) prosecutions)
State v. Deng Kon Tong, 805 N.W.2d 599 (Iowa 2011) (deferred judgment following a guilty plea can constitute a conviction under Iowa felon‑possession law)
State v. Olsen, 848 N.W.2d 363 (Iowa 2014) (judicial findings of guilt pursuant to plea bargaining are convictions in the ordinary sense for felon‑possession purposes)
United States v. Hollingshed, 940 F.3d 410 (8th Cir. 2019) (applies Rehaif to cases pending on direct review; discusses plain‑error review of Rehaif errors)
Olano, 507 U.S. 725 (1993) (establishes the plain‑error review framework)
United States v. Ford, 703 F.3d 708 (4th Cir. 2013) (post‑trial changes in law that render evidence insufficient do not necessarily bar retrial under double jeopardy)