Background
Aaron Lyons pleaded guilty in 2017 to possessing a firearm as a convicted felon under federal law. At the time, all federal circuits held that the government did not need to prove the defendant knew of their prior conviction status. After the Supreme Court ruled in Rehaif v. United States that such knowledge is required, Lyons filed a motion under Section twenty-two hundred fifty-five of Title twenty-eight of the United States Code, arguing his plea was unknowing. He claimed the Rehaif decision was too novel to have been raised earlier and that he was actually innocent because he did not know his status.
The court’s reasoning
The court held that Lyons failed to show cause for his procedural default because the legal basis for his claim was not novel. Although the Third Circuit and other courts had previously rejected the argument, multiple circuits had highlighted its potential merit, meaning the building blocks of the claim were available to defense counsel. The court also rejected the actual innocence claim, noting the plea record showed Lyons understood his conviction carried a five-year sentence and a ban on gun possession. Consequently, the record conclusively showed he knew his status, foreclosing the need for an evidentiary hearing.
What it means going forward
Federal prisoners cannot use the novelty of a new legal interpretation to bypass procedural default rules if the argument’s foundation was already present in existing case law. Courts will likely deny evidentiary hearings on actual innocence claims where the plea record establishes the defendant’s awareness of their conviction status.