He claims that, at the time, he did not know that he was a felon.See 18 U.S.C. § 921(a)(20) ("What constitutes a conviction of [a felony] shall be determined in accordance with the law of the jurisdiction in which the proceedings were held."); State v. Tong, 805 N.W.2d 599, 603 (Iowa 2011) ("[A] deferred judgment constitutes a [felony] conviction ... where the defendant (as here) has not completed his term of probation."); United States v. Reth, 258 F. App'x 68, 69 (8th Cir. 2007) (unpublished per curiam) (same interpretation of Iowa law). When a defendant brings a Rehaif claim, arguing that the knowledge-of-status evidence was insufficient to support his conviction, we review the claim de novo.

Under Iowa law, a deferred judgment constitutes a conviction for purposes of 18 U.S.C. § 922(g)(1). See U.S. v. Reth, No. 06-CR-0159-LRR, 2007 WL 1058467 (N.D. Iowa Apr. 5, 2007), affirmed 258 F. App'x 68 (8th Cir. 2007). To determine whether a conviction has been expunged pursuant to 18 U.S.C. § 921(a)(20), the Sixth Circuit looks to state law.

Defendant argues that a plea of guilty alone is insufficient to constitute a conviction. He argues that the court should apply the same test that it previously applied to a related issue in United States v. Reth, No. 06-CR-159-LRR, 2007 WL 1058467 (N.D. Iowa Apr. 5, 2007), aff'd, 258 F. App'x 68 (8th Cir. 2007). Defendant claims that under that test, which originated in Schilling v. Iowa Dep't of Transp., 646 N.W.2d 69 (Iowa 2002), a guilty plea is only one of four required elements of a conviction, and that the other elements are absent in this case.

We note that Tong's probation agreement prohibited him from possessing firearms. See Saadiq v. State, 387 N.W.2d 315, 323 (Iowa 1986) (rejecting both statutory and constitutional challenges brought by a defendant who had been convicted under section 724.26 and observing that this defendant “was told by his probation officer that he was not to have guns in his possession”); see also United States v. Reth, 258 Fed.Appx. 68, 69 (8th Cir.2007) (holding that a deferred judgment from an Iowa court amounts to a felony conviction under Iowa law for purposes of the federal felon-in-possession statute, 18 U.S.C. § 922(g)(1)).We do not decide today whether a person who has received a deferred judgment and has successfully completed probation has been “convicted of a felony” within the meaning of section 724.26.