Whether the Reed rule applies to a Rehaif v. United States claim

QUESTION PRESENTED A claim not raised on direct review “may be raised in habeas [] if the defendant can [] demonstrate [] ‘cause’ and actual ‘prejudice.” Bousley v. United States, 523 U.S. 614, 622 (1998) (citation omitted). As to cause, if the claim was contrary to “a near-unanimous body of lower court authority” at the time of direct review, but was later endorsed by this Court, then not raising the claim on direct review “is sufficiently excusable to satisfy the cause requirement.” Reed v. Ross, 468 U.S. 1, 17 (1984) (citation omitted). The question presented, which evenly divides four circuits, is whether the Reed rule applies to a claim brought under Rehaif v. United States, 139 S. Ct. 2191 (2019), which “overturn[ed] the long-established interpretation of an important criminal statute, 18 U.S.C. § 922(g), an interpretation that ha[d] been adopted by every single Court of Appeals to address the question.” Id. at 2201 (Alito, J., dissenting). i