Background
Willie Richard Minor was convicted in 2010 under Maine law for simple assault against his then-wife, a charge reduced from domestic violence assault. Seven years later, he was federally charged under Section nineteen hundred and twenty-four subsection a two and Section nine hundred and twenty-two subsection g nine for possessing a firearm. After an initial conviction was vacated due to jury instruction errors regarding the Rehaif standard, Minor was retried. He challenged the statute under the Second Amendment and sought to introduce evidence that he believed he could legally possess a firearm due to his plea arrangement, which the District Court excluded.
The court’s reasoning
The Court held that Section nine hundred and twenty-two subsection g nine is consistent with the historical tradition of firearm restrictions under the Bruen test. Regarding the knowledge element, the Court clarified that a defendant need only know the factual characteristics of their prior conviction that satisfy the statutory definition of a misdemeanor crime of domestic violence, not that they knew the offense was legally classified as such under federal law. The Court affirmed the exclusion of evidence regarding Minor’s subjective belief about his rights, deeming it irrelevant to the statutory elements and potentially prejudicial.
What it means going forward
The decision reinforces the federal prohibition on firearm possession by individuals with prior misdemeanor domestic violence convictions and clarifies that subjective misunderstandings of legal rights do not negate the knowledge element of the offense.