Whether the Ninth Circuit's failure to address Colorado's restoration statutes withstands constitutional scrutiny

QUESTIONS PRESENTED Petitioner K. Jeffery Knapp is man who owned and operated a successful Montana business. He is a man who had a past, having served prison time for Colorado offenses incurred when he was a juvenile. Petitioner is also a man who was specifically advised he was unconditionally discharged when he walked out of the prison doors in 2003 and who knew, at that time, his rights were restored. In 2019, however, Petitioner faced a charge of being a prohibited person in possession of firearms and ammunition despite his unconditional discharge status and despite Colorado’s restoration statutes. Against this background, the following questions are presented: 1. WHETHER THE NINTH CIRCUIT’S FAILURE TO ADDRESS COLORADO’S RESTORATION STATUTES WITHSTANDS CONSTITUTIONAL SCRUTINY WHEN ANALYZING THOSE STATUTES AGAINST THIS COURT’S AND OTHER CIRCUIT COURT’S EX POST FACTO DECISIONS. 2. WHETHER THE NINTH ~ CIRCUIT’S HOLDING UNCONSTITUTIONALLY ENDORSES A BURDEN SHIFT BY THE GOVERNMENT, WHERE THE GOVERNMENT DID NOT CONTRADICT PETITIONER’S TESTIMONY ABOUT HIS KNOWLEDGE OF HIS UNCONDITIONAL DISCHARGE STATUS OR HIS RESTORATION OF RIGHTS. ii