United States v. Ronald Collins
982 F.3d 236
4th Cir.2020Background
- In 2013 Collins was involuntarily committed to Sharpe Hospital after a competency evaluation found him psychotic and incompetent to stand trial; he was later restored and the state charges were dismissed in 2015.
- On January 6, 2018 Collins answered "No" on ATF Form 4473 to whether he had ever been adjudicated as a mental defective or committed to a mental institution and purchased a 9mm handgun.
- Police later found the handgun on Collins and, after ATF involvement, executed a search warrant and arrested him.
- A federal grand jury indicted Collins on (1) making a false statement on ATF Form 4473 (18 U.S.C. § 922(a)(6)) and (2) possessing a firearm after being adjudicated as a mental defective or committed (18 U.S.C. § 922(g)(4)).
- Collins was convicted by a jury on both counts, sentenced to 60 months imprisonment, and appealed raising Rehaif-related defects, a Second Amendment as‑applied challenge, and sentencing challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Indictment omission of Rehaif element | Indictment failed to allege Collins knew he belonged to a prohibited class (Rehaif) | Count One and trial evidence gave notice of Collins's commitment status; omission not prejudicial | No reversible plain error—defendant failed to show prejudice because the false‑statement count and evidence established knowledge |
| Jury instruction omission of Rehaif element | Trial court did not instruct jury that government must prove Collins knew his prohibited status | Jury convicted Count One which required proof that Collins knew he had been committed, so omission harmless | Harmless beyond a reasonable doubt—the jury necessarily found the knowledge element via Count One |
| Second Amendment as‑applied challenge | Collins: his temporary competency commitment under W. Va. law is not the kind of commitment covered by § 922(g)(4) | Commitment to restore competency falls within the ordinary meaning of "committed" under § 922(g)(4) | Rejected Collins’s claim—Midgett controls; § 922(g)(4) applies |
| Sentence procedural/substantive reasonableness | Collins: court failed to consider his arguments and the sentence (60 months) was an unreasonable variance | District court considered §3553(a) factors, explained reasons for variance (public safety, threats, ongoing interest in weapons) | Affirmed—court adequately considered arguments and justified the variance; sentence reasonable |
Key Cases Cited
- Rehaif v. United States, 139 S. Ct. 2191 (2019) (requires proof that defendant knew his prohibited status under § 922(g))
- Olano v. United States, 507 U.S. 725 (1993) (plain‑error test for appellate review of forfeited errors)
- United States v. Cotton, 535 U.S. 625 (2002) (indictment sufficiency and preservation rules)
- United States v. Medley, 972 F.3d 399 (4th Cir. 2020) (failure to allege Rehaif element can be plain error where defendant lacked notice)
- United States v. Brown, 202 F.3d 691 (4th Cir. 2000) (jury omission harmless where jury necessarily made omitted finding)
- District of Columbia v. Heller, 554 U.S. 570 (2008) (Second Amendment protects individual right; bans on mentally ill are presumptively lawful)
- United States v. Midgett, 198 F.3d 143 (4th Cir. 1999) (commitment to restore competency counts as "committed" under § 922(g)(4))
- United States v. Zuk, 874 F.3d 398 (4th Cir. 2017) (district court must explain and justify the extent of a variance from the Guidelines)