In the United States Court of Appeals For the Seventh Circuit ____________________ No. 19‐1358 UNITED STATES OF AMERICA, Plaintiff‐Appellee, v. CHARLES WILLIAMS, Defendant‐Appellant. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:17‐cr‐00446‐1 — Virginia M. Kendall, Judge. ____________________ ARGUED DECEMBER 12, 2019 — DECIDED JANUARY 10, 2020 ____________________ Before BAUER, EASTERBROOK, and ST. EVE, Circuit Judges. ST. EVE, Circuit Judge. The Supreme Court’s recent decision in Rehaif v. United States, 139 S. Ct. 2191 (2019), upset what was once a seemingly settled question of federal law. The Courts of Appeals had unanimously concluded that 18 U.S.C. § 922(g), which prohibits several classes of people from pos‐ sessing a firearm or ammunition, required the government to prove a defendant knowingly possessed a firearm or ammu‐ nition, but not that he knew he belonged to one of the 2 No. 19‐1358 prohibited classes. See, e.g., United States v. Lane, 267 F.3d 715, 720 (7th Cir. 2001). The Supreme Court in Rehaif corrected this misinterpretation and held that under 18 U.S.C. §§ 922(g), 924(a)(2), the government must show “that the defendant knew he possessed a firearm and also that he knew he had the relevant status when he possessed it.” 139 S. Ct. at 2194. Charles Williams had already pleaded guilty to possessing a firearm after a felony conviction when the Court issued Rehaif, and his plea reflected the law as it was in this Circuit before that decision. He seeks now, for the first time on direct appeal, to withdraw his plea. We conclude that he bears the burden of showing that his erroneous understanding of the elements of § 922(g) affected his substantial rights—his decision to plead guilty—before he may do so. He has failed to carry that burden, so we affirm the judgment. I. In 1998, an Illinois state court convicted Williams, then a teenager, of first‐degree murder and sentenced him to thirty years’ imprisonment. Williams was paroled in 2008, but had his parole revoked for the last few months of 2011 based on a domestic battery charge. He pleaded guilty to this offense and served 180 days in jail. Because of his murder conviction, the court could have sentenced him to up to three years’ impris‐ onment. See 720 ILCS 5/12‐3.2(b); 730 ILCS 5/5‐4.5‐45. Williams had no other criminal history until 2017, when he traded cocaine to his employer for a firearm. His employer cooperated with the government and conducted a controlled buy to purchase the gun back from Williams. For this transac‐ tion, a grand jury indicted Williams on one count of posses‐ sion of a firearm as a felon, 18 U.S.C. §§ 922(g)(1), 924(a)(2). No. 19‐1358 3 Williams pleaded guilty without a plea agreement, and the district court conducted a thorough colloquy to determine whether this plea was knowing and voluntary. The court con‐ firmed Williams’s admission that he possessed a firearm; that prior to his possessing that firearm, it had traveled in inter‐ state commerce; and that ...
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