Can the appellate courts' divergent approaches to plain error review of pre-Rehaif guilty pleas be reconciled with one another?

QUESTION PRESENTED In Rehaif, v. United States, this Court held that “in a prosecution under 18 U.S.C. § 922(g) and § 924(a)(2), the Government must prove both that the defendant knew he possessed a firearm and that he knew he belonged to the relevant category of persons barred from possessing a firearm.” 139 8. Ct. 2191, 2200 (2019). Since then, the federal Courts of Appeals have taken divergent approaches to plain error review of pre-Rehaif guilty pleas, where, as here, the defendant argues that his guilty plea was unknowing and involuntary because he was affirmatively misinformed about the critical elements of his § 922(g) offense. As a majority of Circuits have held, does an appellant seeking reversal based on Rehaif overcome plain error review only if he makes a specific showing that he would not have plead guilty, but for the error? Or, as the Fourth Circuit has determined, does a pre-Rehaif guilty plea present a “structural” error that automatically satisfies the third prong of plain error review and requires reversal? The question presented is: Can the appellate courts’ divergent approaches to plain error review of pre-Rehaif guilty pleas be reconciled with one another? Are the federal Courts of Appeals reviewing Rehaifrelated errors in a manner that is contrary to this Court’s precedent in Henderson v. Morgan, 426 U.S. 637, 646-47 (1976)? i