United States v. Edward Malone Lawson, 19-13284

Lawson was indicted under 18 U.S.C. § 922(g)(1) for possessing a Hi-Point .45 after prior felony convictions and pled guilty pursuant to a written plea agreement.
The plea agreement acknowledged a potential 15‑year mandatory minimum under the ACCA and contained a sentence‑appeal waiver (except for three narrow exceptions).
At the change‑of‑plea colloquy Lawson admitted possessing the gun and that he was guilty; the court did not expressly advise him of the Rehaif knowledge‑of‑status element.
The PSR documented multiple prior felony convictions (sodomy, rape, and five drug convictions) and substantial periods of incarceration.
Lawson objected at sentencing only to the ACCA enhancement to preserve the issue; he later moved for a new trial and reconsideration of sentence, which the district court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court plainly erred under Rehaif by failing to advise of the knowledge‑of‑status element at the plea colloquy	Government: Error was plain but caused no prejudice because Lawson would have pleaded guilty anyway; record shows he knew his felon status	Lawson: Plea was not knowing/voluntary because court did not inform him that he must know he was a felon when possessing the firearm	Affirmed conviction — no plain‑error relief because Lawson did not claim he would have gone to trial or identify evidence he did not know his status; record provides overwhelming evidence of knowledge
Whether Lawson may challenge the substantive reasonableness of his ACCA sentence despite the appeal waiver	Government: Valid, knowing, voluntary appeal waiver bars substantive‑reasonableness challenge (Lawson does not invoke an exception)	Lawson: Sentence substantively unreasonable given age of convictions, disability, and that gun was for protection	Dismissed sentence appeal — waiver is enforceable; Lawson does not argue any applicable exception

Rehaif v. United States, 139 S. Ct. 2191 (2019) (holding the government must prove a defendant knew both that he possessed a firearm and that he belonged to the category barred from possessing one)
United States v. Jackson, 120 F.3d 1226 (11th Cir. 1997) (prior Eleventh Circuit precedent on § 922(g) mens rea)
United States v. Reed, 941 F.3d 1018 (11th Cir. 2019) (recognizing Jackson was abrogated)
United States v. Bates, 960 F.3d 1278 (11th Cir. 2020) (Rehaif prejudice analysis where multiple prior felonies produced overwhelming evidence of knowledge)
United States v. McLellan, 958 F.3d 1110 (11th Cir. 2020) (no Rehaif prejudice where lengthy incarceration made knowledge of status inconceivable)
United States v. Innocent, 977 F.3d 1077 (11th Cir. 2020) (Rehaif prejudice analysis where repeated felonies make knowledge likely)
United States v. Moriarty, 429 F.3d 1012 (11th Cir. 2005) (plain‑error review framework for unpreserved Rule 11 claims)
United States v. Bushert, 997 F.2d 1343 (11th Cir. 1993) (standards for enforcing sentence‑appeal waivers)
United States v. DiFalco, 837 F.3d 1207 (11th Cir. 2016) (de novo review of waiver validity)
United States v. Tejas, 868 F.3d 1242 (11th Cir. 2017) (arguments abandoned if not developed with authority)
United States v. Benton, 988 F.3d 1231 (10th Cir. 2021) (Rehaif does not require proof that defendant knew he was "violating the law")