United States v. Wilson

Full title: UNITED STATES OF AMERICA, Plaintiff-Appellee, v. RASHIA WILSON…

Court: UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT

No. 15-11089 No. 15-11090

Date published: May 11, 2016

Fact:

On July 16, 2013, Rashia Wilson, having entered guilty pleas, was sentenced to prison for a total of 252 months in two consolidated cases, a Fraud Case and a Gun Case, to prison terms totaling 252 months. The plea in the Fraud Case was to one count of wire fraud (filing false federal income tax returns to obtain refunds), 18 U.S.C. § 1343, and one count of aggravated identity theft, 18 U.S.C. § 1028A. The plea in the Gun Case was to two counts of felon in possession of a firearm, 18 U.S.C. § 922(g)(1). Wilson appealed her sentences, claiming that the district court erred in grouping the counts under Chapter Three, Part D of the Sentencing Guidelines and in using the sentences imposed in the Gun Case to increase her Criminal History Category for the Fraud Case. 

Issue:

Decision:

The decision in this case is to interpret the relevant statute in a manner that requires the government to prove that the defendant knew he was committing a crime. This decision is based on the principle that it is wrong to convict a person of a crime if they had no reason to believe that their actions were criminal or wrongful. The court concludes that in the unusual circumstances of this case, where the law is obscure and the defendant had no reasonable opportunity to learn about it, the government should be required to prove knowledge of the law to secure a conviction. Therefore, the court orders a new trial for the defendant, Carlton Wilson, where the government would have to prove that he knew that continued possession of guns after the restraining order was entered was a crime.

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