United States v. Leon Ward, 957 F.3d 691

On May 27, 2017, witnesses reported Leon Ward fired shots from a blue Chevrolet Impala; officers later found a silver-and-black Springfield Armory XD .40 and spent .40 casings near where Ward was found with a gunshot wound. The firearm had been reported stolen a month earlier.
Ward has two prior felony convictions (state aggravated robbery and federal brandishing-a-firearm conviction), served prison time, and was on supervised release at the time of his later arrest; at trial he stipulated that he was a convicted felon prior to the charged conduct.
The government indicted Ward under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm; he was tried on that count (and separately pleaded guilty to an attempted robbery charge).
At trial multiple witnesses identified Ward as shooting or as the owner/driver of the car from which shots were fired; the recovered firearm matched witness descriptions though Ward was not arrested holding the gun.
Ward was convicted and sentenced; on appeal (filed after Rehaif) he argued the indictment and jury instructions failed to include the Rehaif knowledge-of-status element and alternatively that the evidence was insufficient.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Indictment adequacy under Rehaif	Indictment did not allege knowledge that Ward was a felon	Indictment tracked statute and provided adequate notice; no contemporaneous objection	Indictment was sufficiently informative; no plain-error reversal on this basis
Jury instructions / plain error (knowledge-of-status)	Failure to instruct jury that Ward must have known he was a felon requires reversal under Rehaif	Ward stipulated to being a felon and record supports inference he knew his status, so any omission was not prejudicial	No plain error: stipulation and record evidence mean outcome likely unchanged
Sufficiency of the evidence	Evidence insufficient to prove Ward possessed the gun and knew he was a felon when possessing it	Witness ID, car ownership, matching gun, and stipulation support possession and knowledge	Evidence sufficient for both possession and knowledge; conviction affirmed

Rehaif v. United States, 139 S. Ct. 2191 (2019) (requires proof that defendant knew he belonged to the category of persons barred from firearm possession)
Old Chief v. United States, 519 U.S. 172 (1997) (limits admissibility of prior-conviction evidence when defendant stipulates)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
Molina-Martinez v. United States, 136 S. Ct. 1338 (2016) (explains reasonable-probability standard for prejudice to substantial rights)
United States v. Vonner, 516 F.3d 382 (6th Cir. 2008) (en banc) (plain-error review framework)
United States v. Cor-Bon Custom Bullet Co., 287 F.3d 576 (6th Cir. 2002) (purpose and liberal construction of indictments)
United States v. Vonn, 535 U.S. 55 (2002) (court may consult whole record when assessing effect of error on substantial rights)