United States v. Phillip Coleman

FLAUM, Circuit Judge.

A jury found Phillip Coleman guilty of four counts of being a felon in possession of a firearm, see 18 U.S.C. § 922(g)(1) (as well as one count of unlawful possession of an unregistered firearm, see 26 U.S.C. § 5861(d); a conviction not in issue here). Coleman attacks the gun convictions on three grounds: 1) that the four felon-in-possession counts were misjoined (or, in the alternative, erroneously not severed); 2) that for one of those counts the government’s evidence was insufficient to establish that the gun traveled in interstate commerce — a necessary element of the…