USA v. Skilar Butler

Defendant appealed his guilty plea conviction of being a dishonorable discharge in possession of firearms where defendant's U.S. Air Force DD-214 certificate of release form ("DD-214") was not sent to him when the Air Force incorrectly believed that it did not have defendant's valid mailing address. At issue was whether defendant knew that he was actually discharged and whether the government had to prove that defendant had knowledge of his status as a felon to establish a violation under 18 U.S.C. 922(g). The court affirmed the conviction and held that the government was not required to prove defendant knew he had been dishonorably discharged from the Air Force at the time of his offense and that defendant's discharge was effective when his DD-214 was ready for delivery.