18 U.S.C. § 922

Section 922(g)(9) withstands a facial challenge under the Second Amendment.

United States v. Bruner · filed 2025-06-02(g)(9)

Thus, the United States argues that Jackson forecloses Appellant Dejuan Dion Bruner’s ... facial challenge to § 922(g)(9), the sole argument made by Mr. Bruner in this appeal. ... Upon consideration, we lift the abatement of proceedings in this appeal which were abated pending a decision in Jackson, and we grant the United States’ unopposed motion for summary affirmance.

Section 922(g)(1)’s ban on firearm possession by felons remains constitutional under the Second Amendment because Rahimi did not abrogate the circuit precedent upholding it.

United States v. Dubois · filed 2025-06-02(g)(1)

We require clearer instruction from the Supreme Court be- fore we may reconsider the constitutionality of section 922(g)(1). Rozier continues to bind us, so Dubois’s challenge based on the Sec- ond Amendment fails.

Facial and as-applied Second Amendment challenges to § 922(g)(1) are foreclosed under Fifth Circuit precedent.

United States v. Carbajal · filed 2025-06-02(g)(1)

First, Carbajal’s as-applied challenge to § 922(g)(1) is foreclosed. See United States v. Schnur, 132 F.4th 863, 870-71 (5th Cir. 2025). Further, as Carbajal correctly concedes, his facial constitutional challenge is likewise foreclosed.

Section 922(g)(1) is constitutional on its face and as applied to nonviolent offenders.

United States v. Adams · filed 2025-05-27(g)(1)

However, we recently reaffirmed the constitutionality of § 922(g)(1)—both on its face and as applied to nonviolent offenders—so we reject Adams’s argument. See Vincent v. Bondi, 127 F.4th 1263, 1265–66 (10th Cir. 2025).

Section 922(g)(1)’s prohibition on firearm possession by felons withstands a Second Amendment challenge under binding Eleventh Circuit precedent.

United States v. Staley · filed 2025-06-09(g)(1)

Staley argues that § 922(g)(1) violates the Second Amend- ment as construed by the Supreme Court. Staley’s argument, how- ever, is foreclosed by our precedent.

Section 922(g)(1) is facially constitutional under binding Sixth Circuit precedent.

United States v. Danyelle Amund Phillips, Jr. · filed 2025-06-09(g)(1)

But our court recently held that section 922(g)(1) is facially constitutional. United States v. Williams, 113 F.4th 637, 657 (6th Cir. 2024). As Phillips recognizes, this panel can’t overrule that decision, so we affirm.

Section 922(g)(1)’s prohibition on firearm possession by a person convicted of a felony withstands a facial Second Amendment challenge under Bruen in the Fifth Circuit.

United States v. Robertson · filed 2025-06-10(g)(1)

Shawn M. Robertson appeals following his conviction for possession of a firearm after having previously been convicted of a felony, in violation of 18 U.S.C. § 922(g)(1), arguing that § 922(g)(1) is unconstitutional on its face in light of the test set forth in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, ... 597 U.S. 1 (2022). ... As the Government asserts, the sole issue raised on appeal is foreclosed by United States v. Diaz, 116 F.4th 458, 467 (5th Cir. 2024), petition for cert. filed (U.S. Feb. 18, 2025) (No. 24-6625).

Section 922(g)(1)’s ban on firearm possession by convicted felons is facially constitutional, and Fourth Circuit precedent forecloses Shoffner’s as-applied Second Amendment challenge.

United States v. Shoffner · filed 2025-06-16(g)(1)

Shoffner argues that § 922(g)(1) is facially unconstitutional and unconstitutional as applied to him following New York State Rifle & Pistol Ass’n v. Bruen, in which the Supreme Court held that a firearm regulation is valid under the Second Amendment only if it “is consistent with this Nation’s historical tradition of firearm regulation.” 597 U.S. 1, 17 (2022). We affirm. ... Two of our recent decisions foreclose Shoffner’s challenges on appeal.

Section 922(g)(1)’s prohibition on possession of firearms or ammunition by convicted felons withstands facial and as-applied Second Amendment challenges, including a challenge by a person convicted of a violent felony.

United States v. Smith · filed 2025-06-27(g)(1)

We therefore reject Smith’s challenge to the facial constitutionality of §922(g)(1). ... Smith’s as-applied challenge likewise fails under our decision in Zherka.

Section 922(g)(1)’s prohibition on firearm possession by a person previously convicted of a felony is constitutional under the Second Amendment.

United States v. Centeno · filed 2025-07-01(g)(1)

We conclude that Centeno’s argument is foreclosed by our Court’s recent decision in Zherka v. Bondi, ___ F.4th ___, 2025 WL 1618440 (2d Cir. June 9, 2025), which rejected an ... identical argument and upheld the constitutionality of § 922(g)(1).

Section 922(g)(1)’s prohibition on firearm possession by convicted felons survives this Second Amendment challenge under binding Eleventh Circuit precedent.

United States v. Youngblood · filed 2025-07-02(g)(1)

Given our binding decisions in Dubois and Rozier, we affirm Mr. Youngblood’s conviction under § 922(g)(1).

Section 922(g)(1)’s prohibition on firearm possession by convicted felons withstands a Second Amendment challenge under binding Eleventh Circuit precedent.

United States v. Jones · filed 2025-07-07(g)(1)

We again affirm Mr. Jones’ felon-in-possession conviction. We are bound by Dubois III, which forecloses Mr. Jones’ Second Amendment argument.

Section 922(g)(1)’s ban on firearm possession by convicted felons is not facially unconstitutional under the Second Amendment after Bruen.

United States v. Washington · filed 2025-07-15(g)(1)

Accordingly, we reject Washington’s argument that § 922(g)(1) is facially unconstitutional and we affirm the judgment of conviction.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional under the Second Amendment in the Tenth Circuit after Bruen and Rahimi.

United States v. Isaacson · filed 2025-07-15(g)(1)

Our two opinions—Vincent v. Garland and Vincent v. Bondi—control, requiring us to reject Ms. Isaacson’s constitutional challenge to § 922(g)(1).

Section 922(g)(1)’s prohibition on firearm possession by felons survives facial and as-applied Second Amendment challenges under binding Eleventh Circuit precedent.

United States v. Granger · filed 2025-07-18(g)(1)

Mr. Granger argues that this prohibition runs afoul of the Second Amendment, both facially and as applied to him. But that argument fails because it is foreclosed by this Circuit’s recent precedent.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional under the Second Amendment after Bruen.

Paige v. United States of America (INMATE 1) · filed 2025-07-21(g)(1)

Paige’s claim that his § 922(g) conviction is unconstitutional under the Second Amendment is therefore foreclosed by binding Eleventh Circuit precedent.

Section 922(g)(1)’s prohibition on firearm possession by felons withstands facial and as-applied Second Amendment challenges under binding Eleventh Circuit precedent.

United States v. Virgil · filed 2025-07-29(g)(1)

First, Virgil argues for the first time on appeal that his statute of conviction, 18 U.S.C. § 922(g)(1), is unconstitutional under the Second Amendment, both facially and as applied to him specifi- cally. Dubois II forecloses this argument.

Section 922(g)(1)’s ban on firearm possession by people convicted of crimes punishable by more than one year in prison remains constitutional under the Second Amendment after Bruen and Rahimi.

United States v. Shi-Young Sharper · filed 2025-08-01(g)(1)

In sum, Sharper’s Second Amendment challenge to § 922(g)(1) is foreclosed by Rozier—a decision that neither Bruen nor Rahimi abrogated. We therefore reject it.

Section 922(g)(9)’s ban on firearm possession by people convicted of misdemeanor crimes of domestic violence is constitutional under the Second Amendment.

United States v. Simmons · filed 2025-08-11(g)(9)

Accordingly, and because Simmons offers no basis to distinguish himself from other domestic violence misdemeanants for purposes of assessing the constitutionality of the statute, we conclude that § 922(g)(9) is constitutional, both facially and as applied to him.

Section 922(g)(1) is facially constitutional under the Second Amendment and applies to a convicted felon’s possession of ammunition for self-defense at home.

United States v. Paul Williams, Jr. · filed 2025-08-12(g)(1)

We therefore reject Williams’s challenge to the facial constitutionality of § 922(g)(1).

Section 922(g)(3) may constitutionally disarm an unlawful drug user who presently poses a clear risk to others if armed.

United States v. VanOchten · filed 2025-08-08(g)(3)

Section 922(g)(3) can be applied consistent with these principles: The government can disarm an illegal drug user who presently poses a clear risk to others if armed.

Section 922(g)(8)(C)(ii) is facially valid under binding Fifth Circuit precedent, though an as-applied challenge may still be considered.

United States v. McPherson · filed 2025-08-12(g)(8)(C)(ii)

McPherson agrees that the facial constitutional challenge raised in his motion to dismiss is now precluded. In the light of the intervening precedent, we VACATE and REMAND for consideration by the district court in the first instance of McPherson’s as-applied challenge to § 922(g)(8)(C)(ii).

Section 922(a)(3) regulates the interstate transportation and receipt of firearms and does not violate the Second Amendment as applied when it does not materially burden the ability to keep and bear arms.

United States v. Perez · filed 2025-08-19(a)(3)

Accordingly, we reaffirm Decastro and hold that § 922(a)(3) is a lawful commercial sale regulation that does not materially constrain Lucha El’s Second Amendment right to “keep” and “bear” arms.

Section 922(g)(1) is constitutional as applied to nonviolent felons under binding Ninth Circuit precedent.

United States v. Gordon · filed 2025-08-19(g)(1)

In Duarte, we held that § 922(g)(1) is constitutional as applied to non-violent felons like Gordon. Id. Because Duarte forecloses Gordon’s only argument in his second-in-time § 2255 motion, amendment of Gordon’s original motion would be futile.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons is constitutional under the Second Amendment in the Eleventh Circuit.

United States v. Bain · filed 2025-08-20(g)(1)

Mr. Bain challenges the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits anyone who has been convicted of a crime punishable by more than one year of imprisonment from possessing a firearm. He argues that this prohibition violates the Second Amendment. But that argument is foreclosed by this Cir- cuit’s recent decision in United States v. Dubois.

Section 922(g)(1)'s prohibition on possession of firearms or ammunition by convicted felons withstands a facial Second Amendment challenge after Bruen.

United States v. Delgado · filed 2025-08-27(g)(1)

Accordingly, Delgado’s facial challenge to § 922(g)(1) fails.

Section 922(o)’s machinegun possession ban is constitutional as applied to a person who has not shown that the machineguns he possessed are commonly used for self-defense.

United States v. Morgan · filed 2025-09-02(o)

We reverse the district court’s dismissal of Mr. Morgan’s indictment because § 922(o) is constitutional as applied to him.

Section 922(n)’s temporary restrictions on receiving, shipping, and transporting firearms while under indictment are facially constitutional under the Second Amendment.

United States v. Ogilvie · filed 2025-09-03(n)

Because § 922(n) falls within this historical tradition of firearm regulation, we hold that § 922(n) is facially constitutional.

Section 922(g)(3) may constitutionally prohibit firearm possession by an active, persistent drug user who is presently impaired.

United States v. Seiwert · filed 2025-09-12(g)(3)

Accordingly, § 922(g)(3) survives ... Seiwert’s as-applied and facial challenges under the Second Amendment.

Section 922(g)(1)’s prohibition on felons possessing firearms or ammunition is consistent with the Second Amendment’s text and historical understanding.

United States v. Williams · filed 2025-09-12(g)(1)

This court thus concludes that it is bound by Medina’s holding that Section 922(g)(1) is consistent with the Second Amendment’s text and historical understanding.

Section 922(g)(1)’s prohibition on felons possessing firearms or ammunition remains constitutional under the Second Amendment after Bruen and Rahimi.

United States v. Dial · filed 2025-09-16(g)(1)

Dial’s challenge to § 922(g)(1) fails. We reach this conclusion based on our decision in Dubois III, in which we held that neither Bruen nor Rahimi abrogated Rozier.

Section 922(g)(1)’s permanent disarmament of felons, including nonviolent felons, is consistent with the Nation’s historical tradition of firearm regulation.

United States v. Havins · filed 2025-09-19(g)(1)

Therefore, Havins’s § 922(g)(1) conviction is constitutional.

Section 922(g)(1)’s prohibition on firearm possession by felons is constitutional under the Second Amendment.

United States v. Shaw · filed 2025-09-24(g)(1)

Based on Rozier and Dubois II, we are bound by the panel precedent rule to conclude that § 922(g)(1) is constitutional under the Second Amendment.

Section 922(o)’s prohibition on possessing machineguns is constitutional on its face and as applied to possession of a machinegun.

United States v. Taylor · filed 2025-09-30(o)

We conclude that § 922(o) is constitutional on its face and as applied to Taylor’s conduct in possessing a machinegun.

Section 922(g)(1)’s prohibition on firearm possession by felons remains constitutional under the Second Amendment after Rahimi.

United States v. Rambo · filed 2025-10-20(g)(1)

We remain bound by our decisions in McAllister, Rozier, and Dubois II. We therefore reject Rambo’s constitutional challenges to § 922(g) and AFFIRM his conviction and sentence.

Section 922(g)(1)’s prohibition on firearm possession by felons is facially constitutional under the Second Amendment.

United States v. Buie · filed 2025-10-20(g)(1)

Therefore, “Rozier remains good law,” Dubois, 139 F.4th at 893, and Buie’s facial challenge to the constitutionality of 18 U.S.C. § 922(g)(1) fails.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons is consistent with the Second Amendment under binding Eleventh Circuit precedent.

United States v. Perkins · filed 2025-10-22(g)(1)

Under our prior-precedent rule, we are bound by Rozier’s conclusion that § 922(g) is consistent with the Second Amendment.

Section 922(g)(1)’s prohibition on firearm possession by felons withstands Second Amendment challenges under binding Tenth Circuit precedent.

United States v. McGregor · filed 2025-10-28(g)(1)

At bottom then, Mr. McGregor’s challenge to the constitutionality of 18 U.S.C. § 922(g)(1) is foreclosed by our precedent—as it was when he initially filed his appeal—and we thus reject it.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional under the Second Amendment in the Eleventh Circuit after Bruen and Rahimi.

United States v. Hennison Curry, Jr. · filed 2025-11-12(g)(1)

Mr. Curry’s arguments fail because they are foreclosed by this Circuit’s recent precedent. See United States v. Dubois, 139 F.4th 887, 892–94 (11th Cir. 2025) (concluding that neither Rahimi nor Bruen abrogated this court’s holding in Rozier that § 922(g)(1) is constitutional under the Second Amendment).

Section 922(k) is facially constitutional under the Second Amendment because it leaves functionally identical firearms available and regulates firearms that are not in common use for lawful purposes.

United States v. Gomez · filed 2025-11-17(k)

We conclude that 18 U.S.C. § 922(k) is facially constitutional.

Section 922(g)(1)’s ban on firearm possession by convicted felons withstands Thornton’s facial and as-applied constitutional challenges under binding Fourth Circuit precedent.

United States v. Thornton · filed 2025-10-20(g)(1)

But as Thornton acknowledges, both his facial and as-applied challenges to § 922(g)(1)’s constitutionality are squarely foreclosed by our decisions in United States v. Canada, 123 F.4th 159 (4th Cir. 2024), and United States v. Hunt, 123 F.4th 697 (4th Cir. 2024).

Section 922(g)(8)(C)(ii) is constitutional as applied to a person whose qualifying no-contact order reflects a threat to a victim’s physical safety and who faces serious charges pending trial.

United States v. Vandyke · filed 2025-10-27(g)(8)(C)(ii)

Section 922(g)(8)(C)(ii) is constitutional as applied to VanDyke under the historical traditions of individual disarmament and categorical disarmament.

Section 922(g)(1) is subject to circuit precedent foreclosing facial and as-applied Second Amendment challenges.

United States v. Dudley · filed 2025-10-28(g)(1)

Though Dudley renews his Bruen claims on appeal, he correctly concedes that these claims are foreclosed by United States v. Canada, 123 F.4th 159, 161 (4th Cir. 2024) (holding that “Section 922(g)(1) is facially constitutional because it has a plainly legitimate sweep and may constitutionally be applied in at least some set of circumstances” (cleaned up)), and United States v. Hunt, 123 F.4th 697, 702 (4th Cir. 2024) (reaffirming this court’s pre-Bruen “precedent foreclosing as-applied challenges to Section 922(g)(1)”), cert. denied, No. 24-6818, 2025 WL 1549804 (U.S. June 2, 2025).

Section 922(g)(1) is facially constitutional under the Second Amendment, and Fourth Circuit precedent forecloses as-applied challenges to it.

United States v. England · filed 2025-10-31(g)(1)

England concedes that his challenges to Count 1 are foreclosed by United States v. Canada, 123 F.4th 159 (4th Cir. 2024), and United States v. Hunt, 123 F.4th 697 (4th Cir. 2024). ... The district court therefore properly denied England’s motion to dismiss the indictment.

Section 922(g)(1) withstands a Second Amendment challenge under controlling Second Circuit precedent.

United States v. King · filed 2025-11-03(g)(1)

Finally, King’s challenge to the constitutionality of 18 U.S.C. § 922(g)(1) is foreclosed by Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025).

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional under the Second Amendment after Bruen and Rahimi.

United States v. Johnson · filed 2025-11-03(g)(1)

Here, the government is clearly correct, as a matter of law, that Johnson’s argument as to the constitutionality of § 922(g)(1) is foreclosed by our holding in Dubois II that neither Bruen nor Rahimi abrogated Rozier, and thus, our holding in Rozier that § 922(g)(1) is constitutional continues to be binding precedent for this Circuit.

On plain error review, § 922(g)(1) withstands a facial Second Amendment challenge and an as-applied challenge by a defendant with violent predicate felonies.

United States v. Johnson · filed 2025-11-04(g)(1)

So, in undertaking plain error review, we reject Appellant’s facial challenge. ... Appellant’s crimes surely do not qualify, so it was not plain error to apply § 922(g)(1) to Appellant.

Section 922(g)(1)’s felon possession ban withstands facial and as-applied Second Amendment challenges under binding Second Circuit precedent.

United States v. Williams · filed 2025-11-06(g)(1)

Williams raises both facial and as-applied challenges to the constitutionality of § 922(g)(1), citing New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). Our decision in Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025), forecloses both arguments.

Section 922(g)(1) withstands facial and as-applied Second Amendment challenges by a person with a prior drug trafficking conviction under controlling Fifth Circuit precedent.

United States v. Alexis · filed 2025-11-07(g)(1)

Kennan Alexis, who has a prior drug trafficking conviction, challenges his 18 U.S.C. § 922(g)(1) conviction—both facially and as applied under the Second Amendment. His challenge fails under controlling Fifth Circuit precedent.

Section 922(g)(1) does not facially violate the Second Amendment and may be applied to a person on parole.

United States v. Hughes · filed 2025-11-10(g)(1)

First, we have held that § 922(g)(1) does not violate the Second Amendment on its face. See United States v. Diaz, 116 F.4th 458, 471–72 (5th Cir. 2024), cert. denied, 145 S. Ct. 2822 (2025). Second, Hughes’s as-applied Second Amendment challenge fails because individuals on parole may be disarmed.

Section 922(g)(1)’s prohibition on firearm possession withstands a Second Amendment challenge when the person’s predicate conviction has not been pardoned or found unlawful.

United States v. Coe · filed 2025-11-12(g)(1)

The district court correctly denied Coe’s motion to dismiss the indictment. Coe does not assert that the conviction that prohibits him from possessing firearms has been “pardoned or [that] the law defining the crime of conviction [has been] found ... unconstitutional or otherwise unlawful.” ... His Second Amendment challenge thus fails.

Section 922(g)(1) is facially constitutional, and convictions under it are not susceptible to as-applied Second Amendment challenges in the Fourth Circuit.

United States v. Whitted · filed 2025-11-14(g)(1)

Canada therefore forecloses Whitted’s facial challenge to § 922(g)(1). With respect to Whitted’s as-applied challenge, we have held, post-Bruen, that § 922(g)(1) convictions are not susceptible to as-applied Second Amendment challenges.

Section 922(g)(1)’s ban on firearm possession by people with felony convictions withstands facial and as-applied Second Amendment challenges under binding Eleventh Circuit precedent.

United States v. Morrissette · filed 2025-12-03(g)(1)

We conclude that Morrissette’s facial and as-applied Second Amendment challenges to § 922(g)(1) fail.

Under controlling Second Circuit precedent, § 922(g)(1)’s prohibition on firearm possession by felons remains constitutional after Bruen.

United States v. Woods · filed 2025-12-09(g)(1)

Zherka is controlling and forecloses Woods’ arguments. As a result, Woods’ conviction under § 922(g)(1) was not plain error.

Section 922(g)(1)’s prohibition on firearm and ammunition possession by convicted felons remains constitutional under the Second Amendment after Bruen.

United States v. Scott · filed 2025-12-10(g)(1)

Scott’s constitutional challenge to Section 922(g)(1) is squarely foreclosed by our recent decision in Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025). In Zherka, we affirmed our holding in United States v. Bogle, 717 F.3d 281, 281–82 (2d Cir. 2013), that “Section 922(g)(1) is a constitutional restriction on the Second Amendment rights of convicted felons” and survives Bruen.

Section 922(g)(1) is constitutional on its face and as applied to people with felony convictions, including nonviolent convictions.

United States v. Tonge · filed 2026-01-07(g)(1)

Tonge’s challenge is foreclosed by the decision of this court in Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025). In Zherka, this court held that § 922(g)(1) is constitutional both on its face and as applied to individuals with felony convictions, including those whose prior convictions were nonviolent.

Section 922(g)(1)’s prohibition on firearm possession by felons is constitutional under binding Eleventh Circuit precedent.

United States v. Broaden · filed 2026-01-08(g)(1)

We thus must reject Broaden’s Second Amendment challenge to 18 U.S.C. § 922(g)(1) because it is foreclosed by our holdings in Rozier and Dubois II.

Section 922(o) is constitutional on its face and as applied to possession of a machinegun.

United States v. Isaiah Fisher · filed 2026-01-09(o)

We therefore conclude that § 922(o) is constitutional on its face and as applied to Fisher’s conduct in possessing a machinegun.

Section 922(g)(1)’s ban on possession of ammunition by convicted felons does not violate the Second Amendment.

United States v. Williams · filed 2026-01-21(g)(1)

As they concede, however, this argument is foreclosed by binding circuit precedent. See United States v. Dubois, 139 F.4th 887, 892–94 (11th Cir. 2025) (holding that we remain bound by our holding in United States v. Rozier, 598 F.3d 768, 770–71 (11th Cir. 2010), that § 922(g)(1) does not violate the Second Amendment), petition for cert. filed, (U.S. Dec. 1., 2025) (No. 25-6281). We therefore affirm their § 922(g)(1) convictions.

Section 922(k)'s prohibition on knowingly possessing a firearm with an obliterated serial number is compatible with the Second Amendment.

United States v. Reyna · filed 2026-01-28(k)

Accordingly, we hold that § 922(k) is compatible with the Second Amendment.

Section 922(o)’s prohibition on possessing a machine gun does not violate the Second Amendment.

United States v. Shobert · filed 2026-02-03(o)

Second, Defendant argues that the district court should have dismissed the charge for possessing a machine gun because 18 U.S.C. § 922(o) violates the Second Amendment. We recently addressed and rejected Defendant’s second argument in United States v. Morgan, 150 F.4th 1339 (10th Cir. 2025). Thus, we summarily affirm as to that issue.

Section 922(g)(1)’s prohibition on firearm possession by felons withstands the facial and as-applied Second Amendment challenges raised here.

United States v. Jackson · filed 2026-02-17(g)(1)

Finally, Jackson argues that 18 U.S.C. § 922(g)(1) is unconstitutional on its face and as applied to him. After Jackson filed his opening brief, this Court issued its decision in Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025), upholding the constitutionality of this statute and foreclosing Jackson’s arguments. See id. at 93.

Section 922(g)(1)’s ban on felons possessing firearms remains constitutional under binding Eleventh Circuit precedent.

United States v. Meyer · filed 2026-03-05(g)(1)

In sum, Dubois clearly dooms Meyer’s Second Amendment challenge to § 922(g)(1) and is binding because it does not conflict with Bondi.

Section 922(g)(4) is facially constitutional under the Second Amendment because historical firearm regulations restricted access for people who were mentally ill and dangerous.

Zarky · filed 2026-03-16(g)(4)

Thus Section 922(g)(4) is not facially unconstitutional.

Section 922(o)’s machinegun prohibition does not violate the Second Amendment because machineguns do not receive Second Amendment protection.

United States v. Porter · filed 2026-03-17(o)

This court’s jurisprudence forecloses Porter’s Second Amendment challenge to 18 U.S.C. § 922(o) argument—machineguns “do not receive Second Amendment protection.”

Section 922(g)(9) is facially constitutional and categorically disarms people convicted of misdemeanor crimes of domestic violence without an individualized finding of future dangerousness.

United States v. Ryno · filed 2026-03-18(g)(9)

Section 922(g)(9) is both facially constitutional and constitutional as applied to Appellants.

Section 922(g)(1) withstands facial and as-applied Second Amendment challenges by a purportedly nonviolent felon under controlling Ninth Circuit precedent.

United States v. Miller · filed 2026-03-19(g)(1)

Miller asserts that § 922(g)(1) violates the Second Amendment, both facially and as applied to him as a purportedly non-violent felon. This claim is foreclosed.

Section 922(g)(1)’s ban on firearm possession by convicted felons remains enforceable against constitutional challenges based on Bruen and Rahimi under Eleventh Circuit precedent.

United States v. Leonard · filed 2026-04-08(g)(1)

Leonard’s constitutional challenge to section 922(g)(1) fails.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons withstands an as-applied Second Amendment challenge under binding Eleventh Circuit precedent.

United States v. Scott · filed 2026-04-17(g)(1)

Scott’s as-applied constitutional challenge to § 922(g)(1) is likewise foreclosed by Rozier, which held that Rozier’s purpose for possessing a firearm and the fact that the firearm was constrained to his home was immaterial because felons as a class could be excluded from firearm possession.

Section 922(g)(1)’s prohibition on firearm possession by felons remains constitutional under Tenth Circuit precedent after Bruen and Rahimi.

United States v. Rangel · filed 2026-04-27(g)(1)

Mr. Rangel appeals, arguing the district court plainly erred because § 922(g)(1) is unconstitutional under the Second Amendment in light of New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). ... Because there has been no change in Tenth Circuit law, we affirm the judgment of the district court.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons is constitutional under the Second Amendment under binding circuit precedent.

United States v. Roseboro · filed 2026-05-05(g)(1)

Our binding precedent in Rozier forecloses Roseboro’s argument that § 922(g)(1) is unconstitutional.

Section 922(g)(1) does not violate the Second Amendment, including when applied to people convicted of nonviolent felonies.

United States v. Riddle · filed 2026-05-07(g)(1)

In United States v. McCane, 573 F.3d 1037, 1047 (10th Cir. 2009), we held that § 922(g)(1) does not violate the Second Amendment. ... Therefore, because Vincent and McCane remain binding precedent, we must affirm the district court’s judgment.

A facial challenge to § 922(g)(3) under Bruen and Rahimi is foreclosed by Eighth Circuit precedent.

United States v. Joshua · filed 2026-05-21(g)(3)

on the grounds that § 922(g)(3) is facially unconstitutional under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), and United States v. Rahimi, 602 U.S. 680 (2024). He acknowledges that this argument is foreclosed by our precedent, ... but asks that we overrule those decisions. This we cannot do.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons is constitutional under the Second Amendment.

United States v. Gibbs · filed 2026-06-22(g)(1)

Therefore, we must again reject Gibbs’s argument and hold that Section 922(g) is constitutional.

Section 922(o) can be enforced against possession of a machinegun because machineguns are not protected by the Second Amendment.

United States v. Betties · filed 2026-06-22(o)

Because machineguns are not protected by the Second Amendment, the district court rightly denied Betties’s motion to dismiss the indictment.

Section 922(g)(3)’s prohibition on firearm possession by unlawful users of or persons addicted to controlled substances is facially constitutional under the Second Amendment.

United States v. Torgerson · filed 2026-06-09(g)(3)

David Torgerson argues that the drug-user-in-possession statute, see 18 U.S.C. § 922(g)(3), facially violates the Second Amendment. Circuit precedent, however, forecloses the argument.

Section 922(g)(1) survives a facial Second Amendment challenge because it has constitutionally valid applications.

United States v. Duncan · filed 2026-06-10(g)(1)

Second, our binding precedent recognizing constitutionally valid applications of § 922(g)(1) forecloses Duncan’s facial challenge.

Section 922(g)(3) withstands a facial Second Amendment challenge under Eighth Circuit precedent.

United States v. Zapata · filed 2026-06-18(g)(3)

He argues the district court erred by denying his motion to dismiss the indictment on the ground that the statute is unconstitutional on its face under the Second Amendment. Upon careful review, we conclude that the district court properly denied the motion, as Zapata’s argument is foreclosed by circuit precedent.

Section 922(g)(1) is not facially unconstitutional under controlling Second Circuit precedent.

United States v. Gavalo · filed 2026-06-23(g)(1)

... § 922(g)(1) is facially unconstitutional. But, as Gavalo concedes, this argument is foreclosed by Zherka v. Bondi, 140 F.4th 68 (2d Cir. 2025).

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional under the Second Amendment in the Tenth Circuit after Bruen.

United States v. Farris · filed 2024-01-16(g)(1)

In a joint supplement filed with this court, Farris “agrees that his constitutional challenge to § 922(g)(1) before this Court is foreclosed by McCane and Vincent and [he] does not oppose a summary affirmance for that reason.” Joint Supp. at 2–3. ... In light of Farris’s concession, ... we agree that a summary affirmance is appropriate.

Section 922(g)(1)’s prohibition on firearm possession by convicted felons remains constitutional after Bruen.

United States v. Thawney · filed 2025-06-30(g)(1)

We do not address this argument because Thawney’s facial challenge fails regardless of the appeal waiver.

Section 922(m) prohibits a firearms dealer from making a false entry on ATF Form 4473 when it knowingly sells a firearm to a straw purchaser.

Wiley v. Fleet Farm LLC · filed 2025-09-09(m)

Assuming that allegation is true, Fleet Farm would have made a false entry on ATF Form 4473 in violation of 18 U.S.C. § 922(m), which requires firearms dealers to sign ATF Form 4473 only if the dealer “does not know or have reasonable cause to believe” that the firearms transaction is prohibited, 27 C.F.R. § 478.124(c)(5).

Section 922(m) can apply when a gun seller knows or has reason to believe that information on ATF Form 4473, including the actual buyer’s identity, is false.

Chiapperini v. Gander Mountain Co. · filed 2014-12-23(m)

Additionally, and contrary to Gander’s contention that 18 USC § 922 (m) cannot conceivably apply, the Fourth Department found that the exact same alleged violation can occur *876when a seller knows, or has reason to believe, that the information entered on the ATF Form 4473 is false, including information about the actual buyer.

Section 922(u) supports an aiding-and-abetting conviction for theft from a firearms dealer when the defendant cases the store and directs the thieves which firearms to steal.

United States v. Kuehne · filed 2008-10-28(u)

In the instant case, there was ample evidence from which the jury could convict Kuehne of the offense enumerated in count 2 beyond a reasonable doubt inasmuch as both individuals whom Kuehne allegedly aided and abetted testified that Kuehne “cased” the Rich-Mart and directed them regarding which firearms to steal. Therefore, the district court did not err in denying Kuehne’s motion for acquittal.

Section 922(u) does not require unlawful entry or presence for theft of firearms from a licensed dealer.

United States v. Roy Schmidt, III · filed 2010-10-22(u)

And Schmidt is correct that, under the terms of § 922(u), unlawful entry or presence is not required.

Section 922(u) covers theft from a licensed firearm dealer’s person or premises. Premises theft requires no breaking, unauthorized presence, force, or injury.

United States v. Thompson · filed 2011-10-21(u)

A § 922(u) premises violation requires no breaking or unauthorized presence (as in burglary of a dwelling), no threat of force (as in extortion), no physical injury to the property of another (as in arson) and no actual use of a dangerous device (as with the use of explosives). A § 922(u) premises violation requires harm to neither property nor people.

Section 922(u) requires proof that the dealer from whom the firearms were stolen was federally licensed.

United States v. Barber · filed 2019-08-27(u)

Barber is correct that the government was required to prove that Dutchman was licensed, in order to support one of his convictions.

Section 922(g)(8) does not authorize a state court to confiscate firearms as part of a sentence for violating a state protection order.

State v. Romine · filed 2008-12-09(g)(8)

Although a state court may order a person to remain law-abiding as a condition of probation or release, a state court may not rely on 18 U.S.C. § 922(g)(8) to order the confiscation of firearms belonging to a person convicted of violating Minn.Stat. § 518B.01, subd. 14(b).

Section 922(b)(2) bars firearm transactions that violate state law; officials’ failure to flag a dealer’s reporting errors does not establish reasonable cause to believe the transactions were lawful.

The General Store, I v. Van Loan · filed 2008-12-31(b)(2)

The dealer, not the ATF or the police department, bears the reporting obligation. The ATF’s failure to cite every violation during prior inspections—particularly when faced with a large number of missing firearms—and the Spokane Police Department’s inac- tion do not demonstrate a good faith belief given The General Store’s repeated failure to follow a clear duty. The district court did not err in finding that The General Store violated § 922(b)(2).

Section 922(b)(2) makes firearms dealers responsible for complying with state handgun reporting requirements; agency or police inaction does not establish a good faith belief that a violation is lawful.

General Store, Inc. v. Van Loan · filed 2009-03-31(b)(2)

The dealer, not the ATF or the police department, bears the reporting obligation. The ATF’s failure to cite every violation during prior inspections — particularly when faced with a large number of missing firearms — -and the Spokane Police Department’s inaction do not demonstrate a good faith belief given The General Store’s repeated failure to follow a clear duty. The district court did not err in finding that The General Store violated § 922(b)(2).

Section 922(g)(1) does not require a felon’s firearm possession to be illegal under state law.

United States v. Massey · filed 2017-02-22(g)(1)

The statute contains no requirement ... that the possession be illegal under state law.

Section 922(b)(2) prohibits a licensed dealer from selling or delivering a firearm to a person whose purchase or possession would violate state law.

Oefinger v. Zimmerman · filed 1984-12-19(b)(2)

Section 922(b)(2) of the Gun Control Act also makes it unlawful for a licensed dealer to sell or deliver a firearm to a person in any State where the purchase or possession by that person would be in violation of any State law.

Section 922(g) covers both nonviolent firearm possession and possession of a sawed-off shotgun, so a conviction under it is not categorically a crime of violence.

United States v. Clark · filed 2009-04-30(g)

Clark was previously convicted of violating 18 U.S.C. § 922(g), which prohibits a felon from possessing a firearm. Unlawful possession of a firearm is not per se a crime of violence. However, the statute is broad enough to proscribe possession of a sawed-off shotgun, which is a crime of violence. ... Therefore, § 922(g) is overinclusive, and it was proper for the district court to rely on the (prior) plea agreement and the undisputed facts in the current PSR.

Section 922(g)(1) has no element requiring the use, attempted use, or threatened use of physical force, so a conviction under it does not satisfy the Career Offender Guidelines’ force clause.

United States v. Walker · filed 2018-05-17(g)(1)

Walker's conviction under 18 U.S.C. § 922(g)(1) is not a crime of violence within the meaning of the Career Offender Guidelines, because the statute does not have "as an element the use, attempted use, or threatened use of physical force against the person of another."

Section 922(g) does not require a showing that the offense was violent.

Harris v. United States · filed 2023-03-17(g)

As the Government notes, the crime Petitioner pleaded guilty to, 18 U.S.C. § 922(g), does not require a showing that the offense was violent.

Section 922(g)(1) does not require a crime of violence or incorporate an elements clause.

Takai v. United States · filed 2023-07-25(g)(1)

None of these subsections require a crime of violence or incorporate an elements clause like the one at issue in Toki.

Section 922(a)(1)(A) covers unlicensed firearms dealing, and repeated profitable sales can establish that a person is engaged in that business rather than liquidating a personal collection.

United States v. Brenner · filed 2012-04-30(a)(1)(A)

Therefore, a reasonable juror could have found beyond a reasonable doubt that Brenner was engaged in the business of dealing in firearms, not liquidating his firearms collection.

Section 922(a)(1)(A) prohibits willfully engaging in the business of dealing firearms without a license.

United States v. Shan · filed 2010-01-15(a)(1)(A)

To sustain its burden on proof on this charge, the government had to prove as follows: (1) the defendant engaged in the business of dealing in firearms, (2) that the defendant did not have a license to deal in firearms, and (3) that the defendant acted willfully.

Section 922(a)(1)(A) prohibits an unlicensed person from dealing in firearms for livelihood and profit, including making firearms available for sale with that objective.

United States v. Gabriel Kish, III · filed 2011-03-30(a)(1)(A)

By contrast, Kish and Summers were not federally-licensed firearms dealers, and thus it was not only unlawful for them ... to sell firearms with the principal objective of livelihood and profit, but also to make firearms available for sale with this objective.

Section 922(a)(1)(A) covers firearms kept for resale as part of an unlicensed firearms business, even before those firearms are sold.

United States v. Crudgington · filed 2012-04-11(a)(1)(A)

Rather, as the essential component of his illicit firearms business, it is clear that the firearms in question were being used by Crudgington unlawfully under 18 U.S.C. § 922(a)(1)(A).

Section 922(a)(1)(A) sets no minimum number of firearm sales for unlicensed dealing; two or three quick resales can show a profit motive.

United States v. Gray · filed 2012-04-13(a)(1)(A)

Although Gray argues that the Government only proved that two guns were sold shortly after Gray purchased them, the statute does not establish a minimum threshold for the number of guns sold. That Gray sold only two or three with a short turnaround was enough evidence for the jury to conclude that he had a profit motive in his gun sales.

Section 922(a)(1)(A) requires an unlicensed firearms dealer to have the principal objective of making a profit, but does not require actual profit.

United States v. Shipley · filed 2013-10-17(a)(1)(A)

Furthermore, a conviction requires that the defendant had the “principal objective” of making a profit, but it does not require that he succeeded in that endeavor.

Section 922(a)(1)(A) does not allow a person who cannot obtain a firearms dealer’s license to deal firearms as a consultant for a licensee.

United States v. King · filed 2013-11-15(a)(1)(A)

So too here, an agent who could not have legitimately obtained a license to deal firearms may not deal firearms by positioning himself as a “consultant” for a licensee.

Section 922(a)(1)(A) prohibits dealing in firearms without a federal license; conviction requires proof that the defendant dealt in firearms as a business, lacked a license, and knew the conduct was unlawful.

United States v. Baptiste · filed 2015-04-20(a)(1)(A)

To convict a defendant of dealing in firearms without a license, the Government must show that the defendant: (1) engaged in the business of dealing in firearms; (2) did not have a license issued under federal law; and (3) knew that his conduct was unlawful. ... A jury would therefore be justified in concluding beyond a reasonable doubt that Baptiste engaged in the business of dealing in firearms.

Section 922(a)(1)(A) prohibits dealing in firearms as a business without a license and requires proof that the defendant knew her conduct was unlawful.

United States v. Valdes · filed 2017-03-09(a)(1)(A)

Under 18 U.S.C. § 922(a)(1)(A), it is unlawful for a person to engage in the business of dealing in firearms without a license. ... The district court did not err in denying Tammy’s motion for a judgment of acquittal because there is sufficient evidence to conclude Tammy knew her conduct was illegal.

Section 922(a)(1)(A) prohibits unlicensed firearms dealing as a business for profit, even when it is a side business.

United States v. Focia · filed 2017-09-06(a)(1)(A)

The plain import of this statutory language reflects congressional intent to criminalize the selling of guns as a business—whether as the seller’s sole means of income or as the seller’s side business—by a person who is not a licensed firearms dealer.

Section 922(a)(1)(A) prohibits dealing in firearms without a license; evidence of repeated sales and intent to profit can support a finding that a defendant engaged in that business.

United States v. Kennemer · filed 2019-09-16(a)(1)(A)

Viewing the trial evidence in the light most favorable to the prosecution, a rational juror could find that the evidence showed that Kennemer “engaged in the business” of selling firearms. 18 U.S.C. § 921(a)(21)(C). The jury heard evidence of Kennemer’s high volume of gun sales, admission that he “pretty much” intended to profit, frequent purchases of the same make and model of firearm, and actual profits from the sales. The evidence showed that Kennemer intended to profit from his gun sales.

When a conspiracy involves dealing in firearms without a license under Section 922(a)(1)(A), the jury must find that the conspirators knew their agreed conduct was unlawful.

United States v. Wyatt · filed 2020-07-10(a)(1)(A)

Wyatt’s two conspiracy convictions for conspiring to deal in firearms without a federal firearms license are VACATED because the district court failed to instruct the jury that, to convict Wyatt of each of those two charged conspiracies, they had to find that Wyatt and those with whom he conspired acted willfully; that is, that they knew that they had agreed with each other to do something that was unlawful.

Section 922(a)(1) prohibits dealing in firearms without a license; an allegation without evidence does not establish a violation.

United States v. One Lot of Eighteen Firearms · filed 1971-04-28(a)(1)

Although the complaint alleges a violation of section 922(a) (1) (prohibiting dealing in firearms without a license), there is no evidence of such a violation.

Section 922(a)(1)(A) prohibits dealing in firearms without a license.

Spearman v. United States · filed 1994-08-24(a)(1)(A)

With respect to petitioner’s plea of guilty to count I, dealing in firearms without a license, the court finds that there was a sufficient factual basis for that plea. Petitioner provided explicit details of how the operation was carried out and his description of his conduct falls under the conduct proscribed by 18 U.S.C. § 922, and meets the requirements of Rule 11(c)(1).

Section 922(a)(7) and (8)'s ban on armor-piercing ammunition does not violate the Second Amendment.

Kodak v. Holder · filed 2009-08-26(a)(7), (a)(8)

Therefore, we conclude that the federal ban on armor-piercing ammunition, pursuant to 18 U.S.C. § 922(a)(7), (8), does not violate the Second Amendment.

Section 922(d)(1) prohibits knowing firearm sales to a convicted felon through a straw purchaser.

United States v. Manis · filed 2009-08-26(d)(1)

Therefore, we rule that the district court did not clearly err in finding by a preponderance of the evidence that Manis engaged in unlawful straw purchases with a prohibited person in violation of 18 U.S.C. § 922(d)(1).

Section 922(a)(6) does not treat someone who buys a gun as a gift for a person he believes is a felon as the actual buyer.

United States v. Tubbs · filed 2016-06-08(a)(6)

Consequently, the most natural reading of the instructions to Question 11.a. is that an actual buyer cannot buy a gun as a gift for a third party whom he believes is a felon.

Section 922(x)(2)(A)'s ban on juvenile handgun possession does not violate the Second Amendment or exceed Congress’s Commerce Clause authority.

United States v. Rene E. · filed 2009-08-31(x)(2)(A)

We hold that 18 U.S.C. § 922(x)(2)(A) does not violate the Second Amendment, and we reaffirm our holding in United States v. Cardoza, 129 F.3d 6 (1st Cir. 1997), that section 922(x)(2)(A) does not exceed Congress’s Commerce Clause authority.

Section 922(g)(1)’s prohibition on firearm possession by felons remains valid after Heller against Second Amendment and Commerce Clause challenges.

United States v. Gieswein · filed 2009-09-04(g)(1)

We can quickly dispose of Gieswein’s first two arguments; both are foreclosed by a recent opinion of this court, United States v. McCane, --- F.3d ---, 2009 U.S. App. LEXIS 16557 (10th Cir. July 18, 2009). ... Our fellow panel rejected, post-Heller, Second Amendment and Commerce Clause challenges to the constitutionality of § 922(g)(1).

Section 922(g)(1)’s ban on firearm possession by people convicted of felonies remains constitutional under binding Ninth Circuit precedent after Bruen.

Walker v. United States of America · filed 2023-04-06(g)(1)

But Bruen did not overrule binding Ninth Circuit precedent upholding felon-in-possession laws such as those Plaintiff challenges.

Section 922(g)(1)’s prohibition on firearm possession by felons is constitutional under the Second Amendment without felony-by-felony review.

United States v. Dunn · filed 2023-08-09(g)(1)

Following New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2122 (2022), this court concluded that the felon-in-possession statute is constitutional, and there is “no need for felony-by-felony litigation regarding the constitutionality of § 922(g)(1).” United States v. Jackson, 69 F.4th 495, 502 (8th Cir. 2023), petition for reh’g filed, No. 22-2870 (8th Cir. July 14, 2023). There is thus no plain error in applying the statute to Dunn.

Section 922(g)(1)’s prohibition on firearm possession by people convicted of crimes punishable by more than one year remains constitutional after Bruen.

Walker v. United States of America · filed 2023-09-19(g)(1)

In accord with every other district court within the Ninth Circuit to decide this issue, this Court reaffirms its conclusion that 18 U.S.C. § 922(g)(1) and other federal and California felon-in-possession laws which Plaintiff challenges remain constitutional in light of Bruen.

Section 922(o)(1)’s ban on possessing machineguns is constitutional as applied to a non-felon citizen because the Second Amendment does not protect machineguns.

United States v. Alsenat · filed 2026-04-21(o)(1)

Because section 922(o) is constitutional as applied to Alsenat, his quasi-facial challenge fails.

Section 922(k) requires proof beyond a reasonable doubt that the defendant knowingly possessed the firearm and knew its serial number had been removed, obliterated, or altered.

United States v. Santiago · filed 2009-09-18(k)

To establish a violation of § 922(k), the Government must prove, beyond a reasonable doubt, that Santiago: (1) knowingly possessed the firearm, and (2) had knowledge that the serial number of the possessed firearm had been removed, obliterated, or altered.

Section 922(k) requires the defendant to know that the firearm’s serial number was obliterated or altered.

United States v. Hawkins · filed 2010-04-23(k)

The list of elements of the § 922(k) offense in Hawkins’s factual resume failed to include the element of the defendant’s knowledge of the obliteration or alteration of the serial number, and the district court did not inform Hawkins of this element of the offense.

Section 922(k) requires knowledge that a firearm’s serial number was removed, obliterated, or altered; a jury may infer that knowledge from substantial possession of the gun.

United States v. Norfleet · filed 2010-11-19(k)

Evidence at trial was sufficient to convict Norfleet under § 922(k). ... Because Norfleet had possessed the gun for a substantial period of time, the jury could infer that he knew the serial number had been obliterated.

Section 922(k) requires proof that the defendant knew the firearm’s serial number was obliterated; constructive possession alone does not establish that knowledge.

United States v. Randy Vana Haile, Jr. · filed 2012-06-29(k)

We join our sister circuits in holding that a defendant’s knowledge of the obliterated serial number is an element of the § 922(k) offense.

Section 922(k) requires proof that the defendant possessed the firearm and knew its serial number was obliterated.

United States v. Nicklaus E. Grant · filed 2014-11-24(k)

To establish Grant’s guilt on Count Two, the Government had to prove both that Grant possessed the firearm and that he knew that the serial number was obliterated.

Section 922(k) requires proof that the defendant knew the firearm’s serial number was altered or obliterated.

United States v. Elton Barnes, Jr. · filed 2016-11-03(k)

Under 18 U.S.C. § 922(k) (2012), however, knowledge that a serial number is altered or obliterated is an element of the offense.

A jury may infer the knowledge required by § 922(k) from circumstantial evidence that the defendant knew a firearm had been altered to remove its serial number.

United States v. Naranjo-Rosario · filed 2017-09-15(k)

A reasonable jury could infer from the defendant's delay in opening the door to police that he knew the gun had been altered and that he needed to hide it.

A guilty plea under § 922(k) requires a factual basis showing that the defendant knew or reasonably should have known the firearm’s serial number was obliterated.

United States v. Percival · filed 2002-11-05(k)

Although a factual basis for a plea of guilty may be obtained from a number of sources, see United States v. Goldberg, 862 F.2d 101,105 (6th Cir.1988), in this case no other facts were adduced reflecting whether Percival knew or reasonably should have known the serial number was obliterated. ... The government must establish a factual basis for all the elements necessary to prove a violation of 18 U.S.C. § 922(k) or the district court may not accept Percival’s plea.

A conviction under § 922(k) based on a coconspirator’s firearm possession cannot stand without sufficient evidence that the defendant knew the firearm would have an obliterated serial number.

United States v. Pabellon-Rodriguez · filed 2013-08-16(k)

As noted, Carrasquillo challenges the sufficiency of the evidence underlying his convictions for possessing a firearm in furtherance of a drug trafficking offense in violation of 18 U.S.C. § 924(c)(1)(A) (count three) and possessing a firearm with an obliterated serial number in violation of 18 U.S.C. § 922(k) (count four). ... Because the government concedes that the evidence was not sufficient to establish that Carrasquillo knew Pabellón would possess a firearm carrying an obliterated serial number,2 we need only consider Carrasquillo's challenge to his count three conviction. ... Although we vacate Carrasquillo's conviction and sentence on count four, we need not remand for resentencing.

Section 922(k) requires proof that the defendant knew the firearm’s serial number had been obliterated.

United States v. Green · filed 2022-09-15(k)

Green’s third argument is that he should have been granted an acquittal because there was insufficient evidence for a reasonable jury to conclude he knew that the gun’s serial number had been obliterated. ... On this record, given the links between Green and the gun, a rational jury easily could have found the essential element of knowledge was satisfied beyond a reasonable doubt.

Section 922(k) requires proof that the defendant knew the firearm’s serial number had been removed, obliterated, or altered.

United States v. Lovo-Serrano · filed 2023-10-05(k)

To establish a violation of § 922(k), the Government must prove the defendant knew the relevant firearm’s serial number had been “removed, obliterated, or altered.”

Section 922(k) requires knowledge that a firearm’s serial number has been obliterated, which may be proved by circumstantial evidence.

United States v. Fonguh · filed 2025-11-18(k)

Under this standard, we conclude that there was ample evidence to support the jury’s finding that the defendants were aware of the obliteration of the firearms’ serial numbers and had the necessary mens rea for violating § 922(k).

Section 922(k) requires knowledge that a firearm’s serial number has been obliterated.

United States v. Nji · filed 2025-11-18(k)

Under this standard, we conclude that there was ample evidence to support the jury’s finding that the defendants were aware of the obliteration of the firearms’ serial numbers and had the necessary mens rea for violating § 922(k).

Knowledge that a firearm’s serial number was obliterated may be proved by circumstantial evidence under § 922(k).

United States v. Tita · filed 2025-11-18(k)

Under this standard, we conclude that there was ample evidence to support the jury’s finding that the defendants were aware of the obliteration of the firearms’ serial numbers and had the necessary mens rea for violating § 922(k).

Section 922(g)(1) requires proof that the defendant knew he possessed a firearm, but not that he knew of its interstate connection.

United States v. Hale · filed 2019-03-18(g)(1)

Under United States v. Dancy, 861 F.2d 77, 81-82 (5th Cir. 1988), a § 922(g)(1) conviction “requires proof that the defendant knew that he had received (or possessed or transported) a firearm but does not require proof that he knew that the firearm had an interstate nexus.” United States. v. Schmidt, 487 F.3d 253, 254 (5th Cir. 2007).

Section 922(g)(1)’s interstate commerce element is satisfied by evidence that the firearm previously traveled between states.

United States v. Hoyle · filed 2012-08-28(g)(1)

If believed, the “interstate nexus” testimony, taken as a whole, would allow a rational juror to infer that the gun in this case had “previously traveled in interstate commerce.” Id. at 566-67.

Section 922(g)(1)’s interstate-commerce element is satisfied when a firearm was manufactured in a different state from the state where it was possessed.

United States v. Campbell · filed 2011-08-26(g)(1)

Here, Campbell stipulated to the fact that the gun found in his possession in Tennessee was manufactured in Massachusetts. This stipulation alone satisfies the interstate-commerce element of § 922(g).

Section 922(g)(1)’s interstate nexus requirement can be satisfied by showing that the defendant possessed ammunition in a state other than the one where it was manufactured.

United States v. Luna · filed 2011-08-12(g)(1)

The government can establish the interstate nexus element required under 18 U.S.C. § 922(g)(1) by showing that a defendant "possessed the [ammunition] in a state other than the one in which it was manufactured." United States v. Corey, 207 F.3d 84, 88 (1st Cir. 2000).

Section 922(g)(1)’s interstate-commerce requirement is satisfied when the firearm has a minimal connection to interstate commerce, including when it was manufactured outside the state where the defendant possessed it.

United States v. Jordan · filed 2011-03-16(g)(1)

Jordan’s as-applied challenge to Section 922(g)(1) is also unavailing because the government introduced sufficient evidence to prove that the firearm was manufactured and assembled outside the state of Georgia -- specifically, agents from the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) testified that the gun found on Jordan was sold in the state of Mississippi in 1981, and that the gun was a Smith & Wesson revolver, marked with the words “Made in the USA,” and “Springfield, Massachusetts.”

Section 922(g)(1)’s interstate commerce element is satisfied when the firearm was manufactured in a state other than the one where it was possessed.

United States v. Nash · filed 2010-12-07(g)(1)

A firearm manufactured in a state other than the one in which it was found provides a sufficient relationship to interstate commerce. ... Because the firearm Nash possessed in Minnesota was manufactured in Massachusetts, there is a sufficient interstate nexus to provide federal jurisdiction.

Section 922(g)(1)’s interstate commerce element is satisfied when the firearm previously crossed state lines.

United States v. Harris · filed 2010-10-28(g)(1)

Under Scarborough v. United States, 431 U.S. 563, 577 (1977), this was sufficient evidence to establish a nexus with interstate commerce.

Section 922(g)(1) requires only a minimal nexus to interstate commerce, which proof that the firearm traveled in interstate commerce can establish.

United States v. Thornton · filed 2010-09-03(g)(1)

Section 922(g) “only requires that the government prove some ‘minimal nexus’ to interstate commerce, which it may accomplish by ‘demonstrat[ing] that the firearm possessed traveled in interstate commerce.’” Wright, 607 F.3d at 715–16 (quoting Scott, 263 F.3d at 1274)). Thorton admitted as part of his guilty plea that the firearms he had possessed had traveled in interstate commerce. We conclude that no error occurred, plain or otherwise.

Section 922(g)(1) requires only a minimal connection to interstate commerce, which a firearm's travel across state lines can establish.

United States v. Brown · filed 2010-05-17(g)(1)

Section 922(g) only requires that the government prove some “minimal nexus” to interstate commerce, which it may accomplish by “demonstrat[ing] that the firearm possessed traveled in interstate commerce.”

Section 922(g)(1)’s interstate commerce element can be satisfied by proof that a firearm’s frame crossed state lines.

United States v. Broadnax · filed 2010-03-19(g)(1)

The frame counts as a “firearm” under § 921(a)(3). Thus, evidence that the frame of the firearm was “in and affecting interstate commerce” because it was manufactured in Florida and ended up in Texas is factually and legally sufficient.

Section 922(g)(1)’s interstate-commerce nexus is not jurisdictional.

Ballester v. United States · filed 2010-03-09(g)(1)

Contrary to petitioner’s view, the interstate nexus is not jurisdictional.

Section 922(g)(1) does not require proof that a defendant knew the firearm possession was in or affecting commerce.

United States v. Fulbright · filed 2009-10-07(g)(1)

Fulbright argues that his conviction should be vacated because the word “knowingly” in § 924(a)(2) applies not only to the possession of a firearm proscribed in § 922(g)(1) but also to the fact that such possession was “in or affecting commerce.” We have rejected this contention many times.

Section 922(g)(1)'s interstate-commerce element requires proof that the firearm crossed state lines at some point, but not proof of its precise state of origin.

United States v. White · filed 2009-09-29(g)(1)

We have never required prosecutors to prove the precise state of origin to prove the interstate-commerce element of a § 922(g)(1) charge. The dispositive inquiry is whether the gun crossed state lines at some point. Although the markings on the pistol White used to shoot Hughes do not conclusively establish the state where the pistol was manufactured, they do establish that the pistol was manufactured outside of Illinois. Accordingly, the evidence is sufficient to support the jury’s verdict on the felon-in-possession count.

A firearm manufactured in one state and shipped to another can satisfy § 922(g)(1)’s interstate commerce element.

United States v. Longoria · filed 2009-11-10(g)(1)

The trial testimony established that the firearm was manufactured in Ohio and shipped to Texas, the state in which Longoria resides. The trial testimony further established that Longoria purchased the firearm in Texas. Thus, the Government produced sufficient evidence from which a jury could conclude beyond a reasonable doubt that the firearm possessed by Longoria affected interstate commerce.

Section 922(g)(1) does not require a jury instruction further defining “affected interstate commerce” when the element was not disputed and the defendant requested no definition.

United States v. Akins · filed 2010-01-15(g)(1)

We hold that the district court’s decision not to further define “affected interstate commerce” was not erroneous.

Section 922(g)(1) does not require proof that the defendant knew the firearm had crossed state lines.

United States v. Peters · filed 2010-02-05(g)(1)

The determination that the “knowingly” requirement in Section 924(a)(2) did not extend to Section 922(g)(1) was an alternate holding, not dictum, and thus is binding precedent.