United States v. Dwayne Adams, 20-4484

Dwayne Adams was charged under 18 U.S.C. § 922(g)(9) for possessing a handgun and four rounds after two prior Virginia misdemeanor domestic assault/battery convictions (2005, 2010).
On December 25, 2017, officers responded to shots fired at Adams’s trailer; shell casings and bullet holes were observed; Adams showed officers the gun and was arrested.
Adams initially pled guilty but withdrew the plea after the Supreme Court’s decision in Rehaif v. United States.
At trial Adams sought to call his prior state-court defense attorneys to testify that they did not advise him that his state misdemeanor convictions would count under federal § 922(g)(9); the district court excluded that testimony as irrelevant.
The jury was instructed that the government must prove Adams knew he had the relevant misdemeanor convictions but need not prove he knew his possession violated federal law; the jury convicted and the district court denied a Rule 29 motion; Adams was sentenced to time served.
On appeal the Fourth Circuit affirmed, rejecting Adams’s arguments about Rehaif, the excluded testimony, and the jury instruction.

Issue	Adams’s Argument	United States’ Argument	Held
Sufficiency of evidence under Rehaif (knowledge element)	Rehaif requires proof that Adams knew his prior convictions counted as a § 922(g)(9) "misdemeanor crime of domestic violence" (i.e., knew his status made possession unlawful).	Government must prove Adams knew he possessed a firearm and that he had the relevant status (the convictions); it need not prove he knew that status made possession unlawful.	Affirmed: Rehaif requires knowledge of status, not knowledge that status makes possession illegal; evidence supported that Adams knew his convictions.
Exclusion of prior counsel testimony	Excluding testimony from Adams’s former state-court attorneys prevented him from presenting a defense (structural error).	Testimony was irrelevant because the government did not need to prove Adams knew his status made possession unlawful.	Affirmed: exclusion not an abuse of discretion because the proffered testimony was irrelevant under the correct Rehaif interpretation.
Jury instruction about knowledge of law	Instruction was erroneous because it told jurors government need not prove Adams knew federal law forbade possession.	Instruction correctly stated the law: government need not prove defendant knew possession was illegal; only knowledge of possession and status required.	Affirmed: instruction correctly stated law and did not prejudice Adams.

Rehaif v. United States, 139 S. Ct. 2191 (2019) (addresses mens rea requirement for § 922(g) prosecutions)
Greer v. United States, 141 S. Ct. 2090 (2021) (clarifies that Rehaif requires proof of knowledge of status, not knowledge that status makes possession unlawful)
United States v. Benton, 988 F.3d 1231 (10th Cir. 2021) (holds government must prove knowledge of possession and status, not knowledge that status prohibits possession)
United States v. Bowens, 938 F.3d 790 (6th Cir. 2019) (rejects argument that Rehaif creates an ignorance-of-law defense under § 922(g))
United States v. Moody, 2 F.4th 180 (4th Cir. 2021) (explains Rehaif requires knowledge of status, not knowledge of legal prohibition)