United States v. Saheed Grant, 19-4267

Saheed Jamal Grant pled guilty to being a felon in possession of a firearm under 18 U.S.C. §§ 922(g)(1), 924(e), and was sentenced to 180 months (the 15‑year ACCA statutory mandatory minimum).
Counsel filed an Anders brief on appeal stating no meritorious issues; Grant filed pro se supplemental briefs raising (1) a Rehaif challenge, (2) Guidelines range/sentencing issues, and (3) ineffective assistance of counsel.
The factual basis for the plea included Grant’s post‑Miranda statement admitting a prior felony conviction.
The Government did not file a response brief on appeal.
The district court complied with Rule 11; the PSR’s Guidelines calculation (including the ACCA enhancement) produced the mandatory‑minimum range, which the court imposed after hearing § 3553(a) arguments and allocution.
The Fourth Circuit reviewed the case, addressed the Rehaif claim under plain‑error review, and affirmed conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rehaif invalidates Grant’s conviction	Rehaif requires proof defendant knew he belonged to the category (felon); conviction should be vacated	The plea factual basis shows Grant admitted he was a convicted felon, so Rehaif gives no relief	Affirmed: No Rehaif error; plea and factual basis show knowledge of status; conviction stands
Validity of Guidelines calculation and ACCA enhancement / sentence reasonableness	Challenges to Guidelines range and ACCA enhancement; contends sentencing errors	PSR and district court correctly calculated range; 15‑year statutory mandatory minimum applied; both parties requested that sentence	Affirmed: Procedurally and substantively reasonable; 180‑month mandatory minimum imposed and upheld
Ineffective assistance of counsel	Counsel’s performance was constitutionally deficient	Record does not conclusively establish ineffectiveness; such claims not cognizable on direct appeal	Dismissed on direct appeal; claim may be raised in a § 2255 motion
Adequacy of appellate counsel’s Anders brief / appellate review	Implicitly challenges whether appeal had merit	Counsel complied with Anders; court conducted independent review	Affirmed: Court found no meritorious issues under Anders; directed counsel to notify client of certiorari rights

Anders v. California, 386 U.S. 738 (appointment of counsel may file brief asserting appeal frivolous)
Rehaif v. United States, 139 S. Ct. 2191 (knowledge‑of‑status element required for § 922(g) convictions)
Olano v. United States, 507 U.S. 725 (plain‑error review framework)
Dominguez Benitez, 542 U.S. 74 (substantial‑rights inquiry in guilty‑plea plain‑error review)
Greer v. United States, 141 S. Ct. 2090 (recognizing difficulty of showing lack of knowledge of felon status)
Gall v. United States, 552 U.S. 38 (reasonableness review of sentences on appeal)