Brandon Dante Brooks-Davis v. United States

In Rehaif v. United States, 139 S.Ct. 2191 (2019), this Court held that, in a prosecution under 18 U.S.C. §§ 922(g) and 924(a)(2), the government must prove not only that the defendant knew he possessed a firearm, but also that he knew he belonged to the relevant category of persons prohibited from firearm possession. This term, the Court granted certiorari in Greer v. United States, No. 19-8709, which presents the same question as for Mr. Brooks-Davis: Whether when applying plain-error review based upon an intervening United States Supreme Court decision, a circuit court of appeals may review matters outside the trial record to determine whether the error affected a defendant’s substantial rights or impacted the fairness, integrity, or public reputation of the trial?