Greer v. United States

In Greer v. United States, the Supreme Court addressed the application of its prior ruling in Rehaif v. United States. Gregory Greer was convicted of being a felon in possession of a firearm. On appeal, he argued for the first time that the district court failed to instruct the jury that the government must prove he knew of his status as a convicted felon. The Eleventh Circuit applied plain-error review and upheld his conviction, finding that Greer could not demonstrate a reasonable probability that the error affected the trial's outcome, given his multiple prior felony convictions. The Supreme Court affirmed this decision, clarifying that in felon-in-possession cases, a Rehaif error is not a structural error and that defendants face a high bar to show prejudice on plain-error review when they have stipulated to or do not dispute their prior felon status.

The Supreme Court affirmed the Eleventh Circuit's decision. It held that Gregory Greer failed to demonstrate that the district court's Rehaif error affected his substantial rights, and thus he could not meet the plain-error standard. His conviction was upheld.

The central dispute was whether a defendant who was convicted of being a felon in possession of a firearm, and who did not raise a Rehaif-based objection at trial, could satisfy the plain-error standard's requirement to show that the error affected their substantial rights, particularly when the defendant had multiple prior felony convictions.

The decision reinforced the stringent application of the plain-error standard in federal appeals post-Rehaif. It effectively insulated many pre-Rehaif felon-in-possession convictions from being overturned, as defendants who clearly had prior felony convictions would struggle to show they were prejudiced by a missing jury instruction regarding their knowledge of their felon status. This provided finality and judicial efficiency by preventing a wave of retrials for a common federal offense.