United States v. William Moye

GREGORY, Circuit Judge,

dissenting in part:

The district court’s aiding and abetting instruction requires vacatur of Moye’s conviction on the felon-in-possession charge. Clearly, the district court erred in giving the aiding and abetting instruction for the felon-in-possession charge because the instruction lacked any foundation in evi*404dence.1 When considered alone, this error might have been harmless. In this case, however, the instruction created confusion by suggesting that Moye could be convicted as an aider and abettor on the felon-in-possession charge absent proof that Cooper or Briggs was a felon. Therefore, I dissent from the decision to affirm Moye’s conviction as to the felon-in-possession charge.2

At the close of evidence, the district court instructed the jury that it could convict Moye as a felon in possession of firearms if the government proved

that Mr. Moye had been convicted of a crime punishable by imprisonment for a term exceeding one year and that the State has not restored the defendant’s civil rights following the conviction. Secondly, that he knowingly possessed the firearm that’s charged and third, that the possession was in or affecting interstate commerce.

J.A. 221-22. Moments later, the district court instructed the jury that to convict Moye as an aider and abettor on either count,

the Government would have to prove that the crime that was charged was physically committed by somebody else and further prove that Mr. Moye aided and abetted the commission of the crime.

J.A. 226 (emphasis added).3

These instructions created confusion as to the requisite elements of the felon-in-possession offense in the aiding and abetting context. The phrase “physically committed by somebody else” suggested that only the principal’s physical acts were relevant.4 Although the felon-in-possession offense has a physical requirement — the act of possessing firearms — the offense also has an essential nonphysical requirement — the principal’s prohibited status as a felon. With attention focused only on the principal’s physical acts, a juror might reasonably have concluded that the principal’s prohibited status was not at issue. Alternatively, a juror might have believed that prohibited status and physical possession did not have to reside in the same person.

In addition, the substantive felon-in-possession instruction and the lack of evidence concerning Cooper’s or Briggs’s prior felony convictions reinforced the understanding that their status was irrelevant. First, the felon-in-possession instruction only detailed how Moye might be convicted of being a felon in possession of firearms. Significantly, the district court never expressly instructed the jury that it had to *405find that Cooper or Briggs was a felon. Second, the government presented evidence of Moye’s status as a felon without addressing that of the other two men. Given this glaring inconsistency, the jury could have concluded that evidence of the prohibited status of Cooper or Briggs was unnecessary. Thus, the jury could have believed that only Moye’s prohibited status was at issue.

Ultimately, the language and context of the instructions did not make clear that either Cooper or Briggs needed to be a felon in order to convict Moye on an aiding and abetting theory. Absent a clear understanding that Cooper or Briggs had to be a felon, jurors could have convicted Moye as an aider and abettor even if they were aware that these two men were not felons. Alternatively, the jurors could have been distracted by the other evidence of criminality — Moye’s status as a felon, the theft of the firearms, the burglary, and the car theft — all of which is irrelevant to a conviction for aiding and abetting a felon in possession.

For these reasons, applying a general presumption that jurors follow instructions cannot cure the error in offering the instruction. Because the government did not and cannot show that the error was harmless, I dissent.

. An aiding and abetting instruction, like all jury instructions, is proper only "if there is a foundation in evidence to support it.” United States v. Schnabel, 939 F.2d 197, 203-04 (4th Cir.1991). Here, there was no foundation in the evidence to support an aiding and abetting instruction because the government introduced no evidence that Briggs or Cooper was a felon.

. I would affirm Moye’s conviction on the possession of stolen firearms charge.

. During trial, Moye’s counsel objected to the aiding and abetting instruction with respect to the felon-in-possession charge, stating, "I don't know how you aid and abet yourself.” J.A. 129. The district court immediately replied, "Well, I don’t have a problem with that. I don't have a problem with that.” Id.

Only after the verdict did the district court acknowledge that "[ajiding and abetting doesn’t work.... Aiding and abetting requires ... somebody else to have committed the crime. Nobody else committed the crime.” J.A. 263.

. In fact, both the district court in its instructions and the government during closing argument repeatedly used the word "physically” to refer to the act of possessing firearms. See, e.g., J.A. 223, 236.