## Facts

- ATF Special Agent Matthew White and other agents went to Aaron Jackson’s apartment and asked whether he had any firearms or ammunition.
- Jackson showed the agents a safe containing a quantity of ammunition.
- The agents seized the ammunition.
- The United States charged Jackson with possessing ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1).
- At trial, to prove the prior-felony element, the government introduced a certified copy of a 1984 New York judgment showing a person named “Aaron Jackson” convicted of unlawful possession of a weapon and a controlled substance.
- The 1984 judgment was roughly eighteen years old by the time of Jackson’s federal trial.
- The government introduced no additional evidence connecting the defendant to the person named in the 1984 judgment (such as date of birth, address, fingerprints, photographs, or testimony from someone with knowledge of the prior case).
- Jackson did not testify and presented no defense witnesses.
- In closing argument, defense counsel argued that the government had not proven beyond a reasonable doubt that the defendant was the same “Aaron Jackson” identified in the 1984 judgment.
- The jury found Jackson guilty, and he appealed on the ground that the evidence was insufficient to prove the prior-conviction element.

## Issues

1. Whether, in a prosecution under 18 U.S.C. § 922(g)(1), a certified conviction record for a person with the same name—without other identifying proof—is sufficient for a rational jury to find beyond a reasonable doubt that the defendant is the person previously convicted.
2. Whether Jackson’s trial conduct (including not presenting rebuttal evidence) amounted to a stipulation, waiver, forfeiture, or other bar to challenging on appeal the sufficiency of the government’s proof on identity.

## Decision

- The Second Circuit held the evidence was insufficient to prove beyond a reasonable doubt that the defendant was the same person as the “Aaron Jackson” named in the 1984 judgment.
- The court rejected the government’s argument that Jackson’s failure to offer rebuttal evidence made the conviction record sufficient.
- The court also rejected the government’s claim that Jackson’s trial conduct estopped him from raising a sufficiency challenge or otherwise functioned as a stipulation to the prior conviction.
- The conviction was reversed and the case remanded for entry of a judgment of acquittal.

## Legal Principles

- On sufficiency review, the question is whether, viewing the evidence in the light most favorable to the government, any rational trier of fact could find the essential elements beyond a reasonable doubt on the trial record.
- In a § 922(g)(1) case, the government must prove beyond a reasonable doubt that the defendant had been convicted of a crime punishable by more than one year, including that the defendant is the person who sustained the prior conviction.
- A conviction record bearing the same name as the defendant, standing alone, ordinarily does not prove identity beyond a reasonable doubt, particularly when the record is many years old and contains no reliable identifying information tying it to the defendant on trial.
- The government may not meet its burden by relying on the defendant’s silence or on the absence of contrary proof; the burden of proof does not shift to the defendant to disprove an element.
- Arguments that the government could have offered stronger identity proof do not cure a failure of proof; sufficiency is measured by the evidence actually admitted at trial.
- A defendant is not barred from challenging sufficiency absent a clear, valid stipulation or other record basis showing the element was conceded; strategic choices by the prosecution about what evidence to present remain the prosecution’s responsibility.

## Conclusion

Because the government proved the prior-conviction element only by introducing an eighteen-year-old judgment for a person with the same name and offered no additional evidence linking that judgment to Aaron Jackson, the Second Circuit concluded no rational jury could find identity beyond a reasonable doubt; it therefore reversed the § 922(g)(1) conviction and remanded for entry of an acquittal.


United States v. Jackson, 368 F.3d 59 (2004)