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The plain-error stand-ard does not apply in this case, and this Court should affirm the judgment below if it determines either that Rehaif er-ror is structural or that the Government cannot carry its burden to show that the error was harmless.
Cassell, Paul, "United States v. Michael Andrew Gary: Brief of Forer United States Court of Appeals for the Fourth Circuit" (2021). Utah Law Faculty Scholarship. 293.