Greer v. United States

Gregory Greer was convicted under 18 U.S.C. Section 922(g) for possessing a firearm as a convicted felon. At his trial, the government was not required to prove that Greer knew he belonged to a class prohibited from possessing firearms, consistent with then-existing precedent. After the Supreme Court's decision in Rehaif v. United States (2019) held that such knowledge is an element of the offense, Greer appealed, arguing that the jury instruction error required reversal. The Supreme Court affirmed the Eleventh Circuit, holding that Greer could not satisfy the plain-error standard because his multiple prior felony convictions made it virtually impossible for a reasonable jury to find he was unaware of his status. The Court concluded the Rehaif error did not affect his substantial rights.

The Supreme Court affirmed Greer's conviction, holding that the Rehaif error did not meet the plain-error standard because Greer could not show a reasonable probability of a different outcome given his extensive felony record.

Whether a Rehaif error—the failure to instruct the jury that the defendant knew of his felony status—requires reversal on plain-error review when the defendant had multiple prior felony convictions and did not object at trial.

The decision limited the retroactive impact of Rehaif, reducing the number of successful appeals by convicted felons. It clarified that defendants must demonstrate actual prejudice from Rehaif errors, and established that a felony record itself strongly supports knowledge of status, shaping lower-court application of mens rea requirements in firearm possession cases.