United States v. Jovon Medley, 972 F.3d 399

Background:

Police recovered a Rock Island .45 and a Glock from Medley after he fled into a D.C. residence; shell casings tied the Rock Island gun to a Prince George’s County carjacking.
Medley pleaded guilty in D.C. to unlawful possession (22 D.C. Code §4503) and was later federally indicted in Maryland for carjacking, a §924(c) firearm charge, and felon-in-possession under 18 U.S.C. §922(g)(1).
The federal indictment and the trial court’s jury instructions did not allege or instruct on the knowledge-of-status element that Rehaif later held required proof that the defendant knew he belonged to the prohibited category.
At trial the jury acquitted Medley of the carjacking and §924(c) counts but convicted him under §922(g); at sentencing the judge found by a preponderance that Medley used the firearm in the carjacking and applied a Guidelines enhancement.
On appeal, after Rehaif, the Fourth Circuit reviewed the unpreserved indictment and instruction errors for plain error, concluded the errors were plain and prejudicial, exercised discretion to correct them, vacated the §922(g) conviction, and remanded with instructions to dismiss that count without prejudice; Judge Quattlebaum dissented.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether omission of Rehaif knowledge-of-status element from the indictment violated Fifth and Sixth Amendment notice rights	Medley: indictment failed to give notice he would have to defend knowledge-of-status, prejudicing his ability to prepare a defense	Government: omission was harmless because record shows outcome would be identical; precedent permits excusing such defects where evidence is overwhelming	Court: omission was plain error and violated substantial rights because indictment did not provide notice; vacated conviction
Whether failure to instruct jury that government must prove knowledge-of-status beyond a reasonable doubt violated the Sixth Amendment/due process	Medley: jury never decided every element beyond a reasonable doubt; omission prejudiced him because he had no notice to contest the element	Government: record evidence (stipulation, prior prison, flight) makes it unlikely outcome would differ; could easily have proved status	Court: instructional error was plain and prejudicial; appellate factfinding would be inappropriate; vacated conviction
Whether the errors affected substantial rights under plain-error (Olano prong 3)	Medley: cumulative omissions compromised indictment notice and jury factfinding and deprived him of opportunity to defend the element	Government: even if error, no reasonable probability of different outcome because evidence was strong	Court: errors affected substantial rights; inability to contest an element that was absent from charging and trial materials meant prejudice
Whether to exercise discretion to correct the plain error (Olano prong 4)	Medley: fairness, integrity, and public reputation of proceedings undermined by combined errors	Government: dominant precedent (Cotton, Neder) counsels against correction when omitted element is supported by overwhelming, uncontested evidence	Court: exercised discretion to notice error—cumulative defects (indictment + instruction + sparse evidence + no opportunity to defend) undermined confidence; remanded to dismiss without prejudice

Key Cases Cited

Rehaif v. United States, 139 S. Ct. 2191 (2019) (§922(g) requires proof defendant knew his prohibited status)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (any fact increasing statutory maximum must be charged, submitted to jury, and proved beyond reasonable doubt)
United States v. Cotton, 535 U.S. 625 (2002) (defective indictment not necessarily jurisdictional; relief depends on effect on proceedings)
Neder v. United States, 527 U.S. 1 (1999) (omitted jury-element errors are subject to harmless-error review if remaining record shows beyond reasonable doubt the verdict would be same)
United States v. Olano, 507 U.S. 725 (1993) (plain-error standard and four-prong framework)
United States v. Promise, 255 F.3d 150 (4th Cir. 2001) (en banc) (analysis of indictment omissions and plain-error review)
United States v. Rogers, 18 F.3d 265 (4th Cir. 1994) (failure to instruct on knowledge element prejudicial under plain-error review)
United States v. Brown, 202 F.3d 691 (4th Cir. 2000) (harmless-error inquiry for omitted elements; three scenarios where omission is non-prejudicial)
United States v. Carrington, 301 F.3d 204 (4th Cir. 2002) (indictment must fulfill notice function; omission may be cured if overt acts provide notice)
United States v. Gary, 954 F.3d 194 (4th Cir. 2020) (Rehaif error in guilty-plea context)