Roland Pulliam was arrested after fleeing from two Chicago police officers. During the chase, both officers saw a gun in Pulliam's hand. Pulliam had previously been convicted of multiple felonies, making it a federal crime for him to possess a gun. The government charged him with possessing a firearm as a felon, 18 U.S.C. § 922(g)(1); Pulliam was convicted after a jury trial.

After Pulliam was sentenced, the Supreme Court decided Rehaif v. United States, ––– U.S. ––––, 139 S. Ct. 2191, 204 L.Ed.2d 594 (2019), which clarified the elements of a § 922(g) conviction. Now, in addition to proving that the defendant knew he possessed a firearm, the government must also prove the defendant belonged to “the relevant category of persons barred from possessing a firearm.” Id. at 2200. This knowledge-of-status element was not mentioned in the jury instructions at Pulliam's trial.

Pulliam now argues that the erroneous jury instructions and three evidentiary errors require the reversal of his conviction. But none of these alleged errors call for the reversal of Pulliam's conviction, so we affirm.

I. Background

In July 2015, Chicago Police Department Officers Victor Alcazar and Jason Guziec responded to a dispatch call that four black men were selling drugs near a fence a few blocks from the officers’ location. Dispatch received this information from two anonymous 911 callers: the first caller reported seeing two drug transactions, while the other observed the men selling “something.” As the officers drove to the reported sale, they noticed four black men standing together near a fence in a McDonald's parking lot. Officer Guziec parked the car and both officers approached the men to conduct a field interview.

The four men dispersed as the officers approached. One of the men—later identified as Roland Pulliam, an employee of a nearby auto body shop—walked between a parked van and the fence. When Pulliam emerged from behind the van, both officers saw a chrome gun in his hand. Officer Guziec yelled “gun” and drew his weapon. Pulliam then ran away from the officers and into a nearby alley. A short way down the alley, Pulliam threw the gun, raised his hands, and allowed Officer Guziec to place him in handcuffs. Officer Guziec escorted Pulliam back to the squad car. Officer Alcazar, having seen where Pulliam threw the gun, went to retrieve it. He found the gun and an ejected magazine near the McDonald's dumpster.

After Pulliam's arrest, Officer Alcazar and other officers searched the parking lot for contraband. The officers found no guns (other than the one discarded by Pulliam) or narcotics in the area. Officer Guziec brought Pulliam to the station and searched him. Pulliam was carrying $408 in cash.

Almost one year later, a grand jury charged Pulliam with possessing a firearm as a felon, 18 U.S.C. § 922(g). Before trial, the government filed a motion in limine seeking a ruling on the admissibility of testimony related to the 911 calls that were relayed by dispatchers to Officers Alcazar and Guziec. Pulliam filed a motion in limine of his own, asking the district court to bar the officers from testifying about the $408 Pulliam possessed. Additionally, Pulliam informed the district court that he planned to elicit testimony from the officers that, during an interview, Pulliam responded to a question by saying “what gun.”

The district court prevented the government from presenting an audio recording of the 911 calls but allowed the officers to testify “as to what the dispatcher told them.” The district court also allowed the government to elicit testimony about the $408 found on Pulliam. Finally, the district court held that Pulliam could not elicit testimony from the officers about his “what gun” remark.

At trial, Officers Alcazar and Guziec testified about receiving the dispatch call, arriving at the parking lot, and the chase and investigation that ensued. The government also called Alison Rees—a fingerprint specialist for the Bureau of Alcohol, Tobacco, Firearms and Explosives—to testify that no fingerprints were recovered from the gun Officer Alcazar recovered.

Pulliam called his boss and the owner of K&M Auto, Marlon Reid, to testify that Pulliam was normally paid in cash on Fridays. In response, the government called a K&M Auto employee to testify that he personally was paid on Saturdays, not Fridays.

A jury found Pulliam guilty of being a felon in possession of a firearm, 18 U.S.C. § 922(g)(1). The district court sentenced Pulliam to 63 months’ imprisonment.

After Pulliam's trial and sentencing, the Supreme Court decided Rehaif v. United States, ––– U.S. ––––, 139 S. Ct. 2191, 204 L.Ed.2d 594 (2019). Rehaif held that, for the government to secure a conviction under § 922(g), the government must prove that a defendant knew he belonged to a category of persons prohibited from possessing a firearm. Id. at 2200. The jury that found Pulliam guilty was not instructed about this knowledge-of-status element.