United States v. Isaac Hobbs
953 F.3d 853
6th Cir.2020Background
- Isaac Hobbs pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
- Indictment alleged Hobbs had prior convictions (including aggravated robbery for which he served six years) and that he knowingly possessed a firearm in interstate commerce.
- District court found Hobbs an armed career criminal under 18 U.S.C. § 924(e) and sentenced him to the 15-year statutory minimum.
- Hobbs appealed; while the appeal was pending, the Supreme Court decided Rehaif v. United States, which requires the government to prove the defendant knew he belonged to the category barred from possessing firearms (i.e., knew he was a felon).
- Hobbs argued the indictment failed to allege the Rehaif knowledge-of-status element and that omission (a) deprived the district court of jurisdiction and (b) rendered his guilty plea unknowing and involuntary.
- The Sixth Circuit rejected both arguments: indictment omissions are non-jurisdictional, and Hobbs failed to show plain-error prejudice to his plea because contemporaneous evidence did not indicate he would have gone to trial and his prior record made proving knowledge straightforward.
Issues
| Issue | Plaintiff's Argument (Hobbs) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Whether omission of Rehaif knowledge-of-status element from the indictment deprived the district court of subject-matter jurisdiction | Indictment failed to charge an essential element (knowledge he was a felon), so the court lacked jurisdiction and the indictment must be dismissed | Indictment defects do not divest the court of jurisdiction; omission is non-jurisdictional | Court: Omission is non-jurisdictional (Cotton, Cor-Bon); district court retained jurisdiction — claim denied |
| Whether Hobbs’s guilty plea was unknowing/ involuntary because the court did not advise him of the Rehaif element | Hobbs lacked notice of the true nature of the charge and would have proceeded to trial if the element had been alleged | Hobbs raised no contemporaneous objection; under plain-error review he must show a reasonable probability he would not have pleaded guilty; record shows no such evidence and proof of knowledge was overwhelming | Court: Plain-error review fails — Hobbs did not show prejudice or contemporaneous evidence he would have rejected the plea; plea stands |
Key Cases Cited
- Rehaif v. United States, 139 S. Ct. 2191 (2019) (holding government must prove defendant knew he belonged to the category barred from firearm possession)
- United States v. Cotton, 535 U.S. 625 (2002) (defects in an indictment do not deprive a court of jurisdiction)
- United States v. Cor-Bon Custom Bullet Co., 287 F.3d 576 (6th Cir. 2002) (Sixth Circuit adopting rule that indictment omissions do not strip subject-matter jurisdiction)
- United States v. Dominguez Benitez, 542 U.S. 74 (2004) (plain-error standard for unpreserved plea objections)
- Lee v. United States, 137 S. Ct. 1958 (2017) (post hoc assertions insufficient; courts should look for contemporaneous evidence showing defendant would have rejected plea)
- United States v. Bowens, 938 F.3d 790 (6th Cir. 2019) (recognizing Rehaif knowledge-of-status requirement applies in § 922(g) prosecutions)