What is the question presented in Sway v. United States?

Whether the district court's failure to inform Petitioner of an essential element of the offense, as required by Rehaif v. United States, 139 S. Ct. 2191 (2019), is a structural error that requires automatic reversal of his conviction?

What is Sway v. United States about?

Sway asked the Supreme Court to review his conviction after the trial court did not tell him that the government had to prove he knew he belonged to a category barred from possessing a firearm, as required by Rehaif. The Court denied review, leaving the Eleventh Circuit’s judgment against Sway in place and allowing the United States to prevail.

When did the Supreme Court decide Sway v. United States?

The Supreme Court decided Sway v. United States on April 20, 2020.

No. 19-7993October Term 2019Decided Apr 20, 2020Updated Sep 3, 2026

Docket 19-7993October Term 2019 (2019–2020)

Sway v. United States

The Court declined review, leaving the Eleventh Circuit's result in place without deciding the legal question.

Case status

Decided · April 20, 2020

Current stage: Decided
Latest event: Decision released Apr 20, 2020

Case Accepted

Arguments

Decision ReleasedApr 20, 2020

What it's about: Sway asked the Supreme Court to review his conviction after the trial court did not tell him that the government had to prove he knew he belonged to a category barred from possessing a firearm, as required by Rehaif. The Court denied review, leaving the Eleventh Circuit’s judgment against Sway in place and allowing the United States to prevail.
Question presented
Whether the district court's failure to inform Petitioner of an essential element of the offense, as required by Rehaif v. United States, 139 S. Ct. 2191 (2019), is a structural error that requires automatic reversal of his conviction?
Case path: United States Court of Appeals for the Eleventh Circuit / Decision released Apr 20, 2020
Area: Decided Supreme Court case

Decision

Decision recordApr 20, 2020

What the Court decided

The Court declined review, leaving the Eleventh Circuit's result in place without deciding the legal question.

Impact

The Eleventh Circuit's result remains in place for Sway. The Court did not resolve whether defendants in similar Rehaif-related cases must automatically receive new proceedings.

Not official Court text.

Briefing

What it's about

The Supreme Court declined to review Sway's case. It did not decide whether failing to explain an essential element of the offense requires automatic reversal of his conviction.

Impact

The Eleventh Circuit's result remains in place for Sway. The Court did not resolve whether defendants in similar Rehaif-related cases must automatically receive new proceedings.

What's next

The Supreme Court has finished this docket action. The case remains governed by the Eleventh Circuit's result.

What did the Supreme Court do in Sway v. United States?

The Court declined to review the case. It did not decide the merits of Sway's Rehaif-related claim.

Who is affected by the Court's action in Sway's case?

Sway remains subject to the Eleventh Circuit's result. Similar defendants did not receive a nationwide answer from the Supreme Court.

What happens next in Sway v. United States?

The Supreme Court's docket action is finished. The Eleventh Circuit's result remains in place.

Timing

Decided April 20, 2020

The Court released its decision on April 20, 2020 without hearing oral argument.

Argument and decision days

Documents

Orders

Lower Court Orders/Opinions

Key filings

Petition

Briefs on file: 2View on supremecourt.gov

View full docket on supremecourt.gov

Activity

Docket activity3

AI analysis generated: Case Briefing
Sep 3, 2026 | Generated
Brief added: Petition
Mar 9, 2020 | Court records
Court Order added: Lower Court Orders/Opinions
Dec 26, 2019 | Court records

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Grounding

Grounding: Primary materials plus reporting.
Note: Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked: Sep 3, 2026
Method: Methodology

Primary materials7

Context reporting4