The Court reversed the defendant’s conviction, holding that the district court’s failure to orally instruct the jury on the elements of the charged offenses was a structural and plain error even where the district court orally confirmed with each juror that they had read the instructions.
The Court held that the “antique firearm defense” was an affirmative defense as opposed to an element of the 922(g). The Court acknowledged that it remains an open question whether the “antique firearm defense” is objective, meaning that the age of the firearm alone determines the availability of the defense, or whether the defense is subjective, meaning the defense applies when a defendant reasonably believes the firearm was manufactured before 1899.
The Court held that it was plain error for the district court to accept the defendant’s plea to armed robbery where the factual basis was based on his placing a closed pocket knife on the bank teller’s counter while pulling a plastic bag out of his pocket, as this did not constitute “use of a deadly weapon.”
The Court held that there was no reasonable suspicion to detain a defendant who fled upon being approached by police as there is no per se rule that says flight creates reasonable suspicion, the officers never ordered the defendant to stop before activating their lights, and there was no threat of harm or indication that the defendant was acting in any dangerous manner or that the area was dangerous.
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