United States v. Paul Richter, 782 F.3d 498

Richter, a convicted felon, was charged with felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
Superseding information covers August 15 to October 20, 2012 in Montana; firearm is Taurus .454 revolver; serial RC634865.
Richter waived his right to a jury trial pre-trial; trial proceeded as a bench trial.
Two key witnesses: Richter’s father testified Richter took the gun; a probation officer testified finding the gun under Richter’s bed and Richter admitting possession.
Richter’s fiancée Kirschten offered an innocent explanation, claiming she retrieved the gun and placed it under Richter’s bed; no openings statements were made, and the judge did not solicit closing arguments.
After evidence, the court recessed briefly and then rendered a guilty verdict without a closing argument; Richter challenged sufficiency of evidence and the closing-argument procedure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for possession	Richter did not possess the firearm.	Evidence shows no clear possession; only inference from others.	Evidence sufficient to sustain conviction.
Waiver of closing argument	District court must solicit closing arguments; error if not.	Richter implicitly waived closing argument.	Richter implicitly waived closing argument; no plain error requiring reversal.

United States v. Nevils, 598 F.3d 1158 (9th Cir. 2010) (standard for reviewing sufficiency of evidence)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency of evidence standard)
United States v. Bell, 770 F.3d 1253 (9th Cir. 2014) (closing argument right and waiver framework)
Herring v. New York, 422 U.S. 853 (U.S. 1975) (closing argument rights foundations)
United States v. Igbinosun, 528 F.3d 387 (5th Cir. 2008) (implicit waiver of closing argument by silence with meaningful opportunity)
United States v. Prince, 772 F.3d 1173 (9th Cir. 2014) (factors for implicit waiver in closing argument)