Does Rehaif v. United States preclude a jury instruction that the federal government must prove a defendant knew his prohibited status made it illegal to possess a firearm when he claims a mistaken belief as to the application of 18 U.S.C. §§922(g) and 924(a)(2)?

QUESTIONS PRESENTED Police arrested Petitioner Damon Willis on three separate occasions for possessing a firearm after having incurred a conviction for an offense punishable by more than one year in prison contrary to 18 U.S.C. § 922(g)(1). Officers testified at trial that Mr. Willis adamantly stated, as a “Sovereign Citizen,” he could lawfully possess any gun he did not deface or take across state lines. The government used Mr. Willis’s mistaken belief that he could possess a firearm to satisfy its burden to prove that petitioner knowingly possessed the firearms in two of the charges for which he did not directly admit knowing physical possession. The trial court instructed the jury the government did not have to prove Mr. Willis knew the law prohibited him from having a gun, an instruction this Court subsequently declared improper in Rehaif v. United States, 131 S. Ct. 2191 (2019), in the case of a man convicted as a non-citizen in possession of a firearm who claimed he did not know the student-visa he used to legally enter the United States had lapsed. Seven circuits have issued published decisions holding that Rehaif precludes judges from instructing juries that the government must prove a defendants knew membership in a category of persons listed in Section 922(g)(1) prohibited the possession of firearms. In light of the foregoing, the issues presented in this case are as follows: Does Rehaif v. United States preclude a jury instruction that the federal government must prove a defendant knew his prohibited status made it illegal to possess a firearm when he claims a mistaken belief as to the application of 18 U.S.C. §§922(g) and 924(a)(2)? Did the instruction in this case deny Mr. Willis’s Fifth and Sixth Amendment rights to present a complete defense? 2