United States v. Thompson — 143 F.4th 169 (2025) · Court of Appeals for the Second Circuit · 2025

Court of Appeals for the Second Circuit · 2025-07-10

18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)

Original case on neochart.com

Case and law context

18 U.S.C. § 922(g)

Role: rule-announced; posture: criminal appeal after guilty plea to § 922(g)(1) with appeal waiver; appeal mainly challenges special conditions of supervised release; pro se Rule 11 (Rehaif) challenge to the plea rejected on plain-error review and remaining challenges held barred by the waiver; affirmed; result: claimant-won; claim:

Uncertainty

None recorded

Misfit

None recorded

B · Case × element grid

Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.

Elements 1–6 of 12

18 U.S.C. § 922(g)
CaseOne applicable prohibited categorySection 925(a)(1) government-use firearm or ammunition exceptionActual or constructive possessionFirearm or ammunition under section 921Possession in or affecting commerceKnowledge of possessing the firearm or ammunition
United States v. Thompson — 143 F.4th 169 (2025) · Court of Appeals for the Second Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 7–12 of 12

18 U.S.C. § 922(g)
CaseKnowledge of the relevant disqualifying statusSecond Amendment limit on the unlawful-user theory applied to HemaniShip or transport in interstate or foreign commerceKnowing shipping, transportation or receiptReceipt of the prohibited objectReceived object previously shipped or transported across borders
United States v. Thompson — 143 F.4th 169 (2025) · Court of Appeals for the Second Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))
○ not reached · basis not recordedNot counted: rule-announced/procedural
· not addressed· not addressed· not addressed· not addressed· not addressed

Instances and excluded annotation blocks

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
United States v. Thompson — 143 F.4th 169 (2025) · Court of Appeals for the Second Circuit · 2025 — not reached (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Knowledge of the relevant disqualifying statusnot_reached
Excluded from merits counts
rule-announced / procedural

party: Kenneth Thompson; count: 18 U.S.C. § 922(g)(1); subject: party=Kenneth Thompson; count=18 U.S.C. § 922(g)(1)

The court decides only that the defendant was TOLD of the knowledge-of-status element (Rule 11(b)(1)(G)), not that he knew his status; the conviction rests on the guilty plea. The opinion approves the magistrate judge's statement of the element.
plea colloquy that recited the Rehaif knowledge-of-status element; plea held knowing, so the appeal waiver is enforced
The magistrate judge explicitly stated to Thompson at his plea hearing that in addition to proving that he “knowingly possessed the firearm and ammunition as charged in the indictment,” “the government would [also] have to prove that [Thompson was] convicted in any court of a crime punishable by imprisonment for a term exceeding one year and that [he] knew [he] had been convicted of such a crime.”
Source: docroot/ir/caselaw/f4th_143.jsonl#/f4th/143/169; Unicode character offsets [40794:41194] (end exclusive); SHA-256 eae341592a474d3e3934da53386f5dc41d81c8bea633cb72b7053894e83445bb.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 1 (1 = tagged; 0 = not tagged)

We find that the district court met its obligations under Rule 11 and sufficiently informed Thompson of the elements of his crime.
Source: docroot/ir/caselaw/f4th_143.jsonl#/f4th/143/169; Unicode character offsets [40663:40793] (end exclusive); SHA-256 eae341592a474d3e3934da53386f5dc41d81c8bea633cb72b7053894e83445bb.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case

interpretation

The magistrate judge explicitly stated to Thompson at his plea hearing that in addition to proving that he “knowingly possessed the firearm and ammunition as charged in the indictment,” “the government would [also] have to prove that [Thompson was] convicted in any court of a crime punishable by imprisonment for a term exceeding one year and that [he] knew [he] had been convicted of such a crime.”

United States v. Thompson — 143 F.4th 169 (2025) · Court of Appeals for the Second Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))

The magistrate judge explicitly stated to Thompson at his plea hearing that in addition to proving that he “knowingly possessed the firearm and ammunition as charged in the indictment,” “the government would [also] have to prove that [Thompson was] convicted in any court of a crime punishable by imprisonment for a term exceeding one year and that [he] knew [he] had been convicted of such a crime.”
Source: docroot/ir/caselaw/f4th_143.jsonl#/f4th/143/169; Unicode character offsets [40794:41194] (end exclusive); SHA-256 eae341592a474d3e3934da53386f5dc41d81c8bea633cb72b7053894e83445bb.

Rehaif expressly reserved the precise proof needed for statuses other than the one before it; do not infer that awareness of every legal consequence or the federal firearms ban is required. Status knowledge must coincide with the relevant conduct.