Michael Anthony Rangel was convicted in the District of Utah for violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms and ammunition. He was sentenced to 84 months in prison. On appeal, Rangel argued that the district court plainly erred by applying the statute, claiming it is unconstitutional under the Second Amendment in light of the Supreme Court's 2022 decision in New York State Rifle & Pistol Ass'n v. Bruen. However, Rangel conceded that existing Tenth Circuit law already forecloses this argument. His primary goal in appealing was to preserve the issue for potential future review, specifically hoping the Supreme Court might grant certiorari and change the law while his appeal was pending.
The panel addressed the core legal question of whether recent Supreme Court jurisprudence has altered the constitutionality of felon-in-possession bans within the Tenth Circuit. The court recalled that in Bruen, the Supreme Court established a framework requiring the government to demonstrate a historical tradition of 'relevantly similar' firearms regulations from the founding era to justify a law that infringes on the Second Amendment. The Tenth Circuit previously addressed this in Vincent v. Garland, holding that Bruen did not abrogate existing case law upholding § 922(g)(1). Although the Supreme Court vacated and remanded Vincent for further consideration in light of United States v. Rahimi, the Tenth Circuit subsequently reaffirmed its position in Vincent v. Bondi. In that decision, the court concluded that Rahimi, which upheld a different statute prohibiting individuals subject to domestic violence restraining orders from possessing firearms, did not undermine the reasoning or result of the earlier Vincent panel. The court in Rangel's case noted that the Supreme Court recently denied certiorari in Vincent v. Bondi. Because there has been no change in Tenth Circuit law, the panel found no basis to disturb the district court's judgment.
Rangel's conviction and 84-month sentence remain in effect. The decision confirms that the Tenth Circuit's precedent upholding 18 U.S.C. § 922(g)(1) remains binding despite the Supreme Court's Bruen and Rahimi decisions. No remand is ordered, and the legal landscape for felon-in-possession cases in the Tenth Circuit remains unchanged unless the Supreme Court subsequently grants certiorari in a case challenging the statute directly.