Juan Anibal Patrone v. United States

First, whether the district court's violation of Rehaif v. United States, 139 S. Ct. 2191 (2019)—when it omitted the knowledge of immigration status element under 18 U.S.C. § 922(g)(5)—entitles a defendant to relief, irrespective of whether the defendant can show a reasonable probability that, but for the error, he would have gone to trial. Second, whether the pattern element of USSG § 4B1.3 requires proof of planned criminal acts that occur over at least one year, rather than weeks or months, where the livelihood element explicitly imposess a time-based requirement of twelve months.