United States v. Guzman-Merced, 984 F.3d 18

In 2013 Guzmán, then 17, was convicted in Puerto Rico of three felonies punishable in law by more than one year, but each sentence was suspended to probation and he served no prison time.
In 2017 Guzmán was involved in a shoot-out; he pled guilty in 2018 to one count of violating 18 U.S.C. § 922(g)(1).
The district court’s Rule 11 plea colloquy did not inform Guzmán of the mens rea element identified in Rehaif v. United States (Decided 2019): that the government must prove the defendant knew he was a felon.
Guzmán raised no contemporaneous objection to the plea colloquy, so the court applied plain-error review on appeal.
The First Circuit found several facts counseling in favor of reasonable doubt about Guzmán’s knowledge: his suspended sentences (no actual prison time), his youth at the time of the prior convictions, diagnosed learning disabilities, and the four-year gap between convictions and the § 922(g)(1) offense.
The court concluded there was a reasonable probability Guzmán would not have pleaded guilty if told of Rehaif’s knowledge requirement, and that the error seriously affected the fairness and integrity of the proceedings; it vacated the plea, conviction, and sentence and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to advise of Rehaif knowledge element at plea colloquy is plain error warranting vacatur	Guzmán: Plea was not knowing/voluntary because he was not informed the government must prove he knew he was a felon	Government: Any error was harmless; the record would have supported overwhelming proof Guzmán knew his prior convictions were punishable by >1 year; benefit of plea (Guidelines reduction) made acquiescence rational	Vacated: Court found clear Rehaif error, prejudice (reasonable probability Guzmán would not have pled), and that the error undermined fairness/integrity, so plain error reversal warranted
Whether the record showed overwhelming proof of Guzmán’s knowledge, negating prejudice	Guzmán: Suspended sentences, youth, learning disabilities, and time gap could have led a jury to doubt his knowledge	Government: Prior convictions legally punishable by >1 year and sentencing court likely explained penalties; acceptance-of-responsibility benefit made plea attractive	Held: Court sided with Guzmán — record did not show overwhelming proof of knowledge and the plea benefit did not foreclose a reasonable probability he would have opted for trial

Rehaif v. United States, 139 S. Ct. 2191 (2019) (holding § 922(g) conviction requires proof defendant knew he had the relevant status)
United States v. Burghardt, 939 F.3d 397 (1st Cir. 2019) (applied Rehaif on plain-error review; found no reasonable probability of different decision)
United States v. Figueroa-Ocasio, 805 F.3d 360 (1st Cir. 2015) (standards for knowing and voluntary plea)
United States v. Gandia-Maysonet, 227 F.3d 1 (1st Cir. 2000) (plea insufficiency and risk of conviction from legal misunderstanding)
United States v. Correa-Osorio, 784 F.3d 11 (1st Cir. 2015) (plain-error framework reference)
United States v. Bryant, 976 F.3d 165 (2d Cir. 2020) (discussing Rehaif and convictions with probationary sentences)