Automated Summary
Key Facts
Darius Deontae Little entered a conditional guilty plea to possession of a firearm by a convicted felon under 18 U.S.C. §§ 922(g)(1), 924(a)(8). He was sentenced to 24 months' imprisonment and three years of supervised release. Little appealed his conviction, arguing that § 922(g)(1) is unconstitutional both facially and as applied to him following the Supreme Court's decision in Bruen. The Fourth Circuit affirmed the conviction, citing binding circuit precedent from United States v. Canada and United States v. Hunt, which upheld the statute's constitutionality.
Issues
- Whether 18 U.S.C. § 922(g)(1) (prohibiting firearm possession by convicted felons) is facially unconstitutional under the Second Amendment, particularly in light of New York State Rifle & Pistol Ass'n v. Bruen (2022) and United States v. Rahimi (2024).
- Whether the application of § 922(g)(1) to the defendant—a nonviolent convicted felon—violates the Second Amendment, given the lack of historical analogues for disarming such individuals.
Holdings
- The court held that the defendant's facial challenge to 18 U.S.C. § 922(g)(1) is foreclosed by binding circuit precedent, reaffirming its facial constitutionality even after the Supreme Court's decision in Rahimi. The opinion cited United States v. Canada, which concluded the statute aligns with Rahimi's requirements.
- The court also rejected the defendant's as-applied challenge to §922(g)(1), determining it is similarly foreclosed by binding circuit precedent. Reference to United States v. Hunt established that even without prior precedent, the statute would pass constitutional scrutiny under current standards.
Remedies
The court affirmed the criminal judgment, upholding the conviction under 18 U.S.C. §§ 922(g)(1), 924(a)(8) and rejecting both facial and as-applied challenges to the statute.
Legal Principles
The Fourth Circuit affirmed the defendant's conviction for possession of a firearm by a convicted felon, concluding that 18 U.S.C. § 922(g)(1) is facially and as-applied constitutional under the Second Amendment. The court emphasized that its decision was bound by prior circuit precedent, including United States v. Canada and United States v. Hunt, which confirmed the statute's validity post-Bruen and Rahimi. The legal principle applied was the adherence to binding circuit law, precluding challenges absent en banc or Supreme Court decisions overturning prior rulings.
Precedent Name
- United States v. Canada
- United States v. Hunt
- United States v. Rahimi
- United States v. Pruess
Cited Statute
Title 18, United States Code
Judge Name
- Keenan
- King
- Wilkinson
Passage Text
- In Little's facial challenge to § 922(g)(1), he cites United States v. Rahimi, 602 U.S. 680 (2024), to argue that his conduct is protected by the text of the Second Amendment and that § 922(g)(1) is inconsistent with this country's history and tradition of firearm regulation. However, in our decision in United States v. Canada, 123 F.4th 159 (4th Cir. 2024), we reaffirmed our holding that § 922(g)(1) is facially constitutional and determined that this conclusion is fully consistent with Rahimi. Id. at 160-62. Little's facial challenge is thus squarely foreclosed by binding circuit precedent.
- We turn next to Little's as-applied challenge to § 922(g)(1). Little argues that the Government has failed to adequately identify any historical traditions or analogues that would justify disarming nonviolent offenders such as himself. Once again, however, binding circuit precedent squarely forecloses Little's argument. In United States v. Hunt, we held that 'neither Bruen nor Rahimi abrogates this Court's precedent foreclosing as-applied challenges to [§]922(g)(1)' and, further, that '[§]922(g)(1) would pass constitutional muster even if we were unconstrained by circuit precedent.' 123 F.4th 697, 702 (4th Cir. 2024), cert. denied, 145 S. Ct. 2756 (2025). Little's as-applied challenge thus also fails under binding circuit precedent.