United States v. Naquel Henderson, 108 F.4th 899

Naquel Henderson pleaded guilty to federal and D.C. charges for unlawful firearm possession as a felon, based on a prior felony conviction for attempted robbery.
His guilty plea was entered before the Supreme Court's decision in Rehaif v. United States clarified that conviction under 18 U.S.C. § 922(g) requires proof the defendant knew both their possession of the firearm and their prohibited status.
Neither Henderson's counsel nor the prosecution informed him of the Rehaif decision’s new interpretation before his sentencing.
Henderson did not directly appeal but filed a motion to vacate his conviction under 28 U.S.C. § 2255, arguing ineffective assistance of counsel and that his plea was not knowing or voluntary.
The district court denied relief, finding Henderson had not shown prejudice nor actual innocence.
The appellate court reviewed de novo and affirmed the denial of Henderson’s § 2255 motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective Assistance	Counsel failed to inform him of the Rehaif requirement, affecting plea decision.	Failure to raise Rehaif was not prejudicial because Henderson knew he was a felon.	No prejudice shown; no relief granted.
Knowing & Voluntary Plea	Plea was not knowing/voluntary without awareness of Rehaif knowledge-of-status element.	Plea was voluntary since Henderson knew his felon status, despite not being told of the new requirement.	No prejudice or involuntariness; no relief granted.
Procedural Default	Should be excused due to constitutional claim and ineffective counsel.	Claim defaulted by lack of direct appeal; no valid excuse or prejudice shown.	No actual prejudice; default not excused.
Actual Innocence	Asserts he was not actually aware of his prohibited status as a felon at the time.	Record shows Henderson knew he was a felon; no reasonable juror would find otherwise.	No showing of actual innocence.

Rehaif v. United States, 588 U.S. 225 (2019) (establishes knowledge-of-status element for § 922(g) convictions)
Strickland v. Washington, 466 U.S. 668 (1984) (sets forth standard for ineffective assistance of counsel)
Hill v. Lockhart, 474 U.S. 52 (1985) (standard for prejudice in plea context for ineffective counsel)
United States v. Frady, 456 U.S. 152 (1982) (establishes higher bar for collateral relief than direct appeal)
Bousley v. United States, 523 U.S. 614 (1998) (discusses procedural default and actual innocence standard in pleas)
Schlup v. Delo, 513 U.S. 298 (1995) (sets standard for actual innocence in collateral attacks)
Greer v. United States, 593 U.S. 503 (2021) (applies Rehaif to collateral review and prejudice analysis)