Latest Case: In re: Sampson (Civil Rights)

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In re: Sampson

Docket: 20-1224

Opinion Date: March 25, 2020

Judge: Per Curiam

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

In 2014, Sampson pleaded guilty to possession of a firearm by a felon, 18 U.S.C. 922(g)(1). The district court denied his motion to withdraw his plea and sentenced him to 15 years' imprisonment. The Third Circuit affirmed. The district court denied his subsequent 28 U.S.C. 2255 motion, finding his claims waived or meritless. Sampson filed a 28 U.S.C. 2244 and 2255(h) motion seeking permission to file a second or successive 2255 motion to vacate, set aside, or correct his sentence. The Third Circuit denied the application, concluding that there was no new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable. Sampson cited the Supreme Court’s 2019 “Rehaif” holding that the government must prove that a defendant charged with violating section 922(g) knew both that he possessed a firearm and that he belonged to the relevant class of persons barred from possessing a firearm. Rehaif did not state a rule of constitutional law but only addressed what the statutes require for a conviction and the rule has not been made retroactive. Sampson was informed that the government was required to prove beyond a reasonable doubt that Sampson knowingly possessed a firearm and pled guilty.