Background
Ralphael Roy Caldwell appealed his conviction for possession of a firearm and ammunition by a convicted felon under Section ninety-two two of Title eighteen of the United States Code, subsection G, paragraph one. He argued that the statute is unconstitutional under the Second Amendment and exceeds Congress’s authority under the Commerce Clause.
The court’s reasoning
The court stated that its precedents control the appeal and foreclose Caldwell’s arguments. It noted that it has repeatedly rejected facial challenges to the constitutionality of the statute under the Commerce Clause. The court also held that the required minimal nexus to interstate commerce exists where the government proved the firearm was manufactured out of state and traveled in interstate commerce. Regarding the Second Amendment, the court held that the Supreme Court’s decision in New York State Rifle and Pistol Association did not abrogate its prior holding that the statute does not violate the Second Amendment. Although the Supreme Court had previously vacated and remanded a related case for consideration in light of United States versus Rahimi, the Eleventh Circuit reinstated its earlier opinion on remand and rejected the argument that Bruen and Rahimi abrogated its holding.
What it means going forward
The ruling reinforces the Eleventh Circuit’s position that Section ninety-two two of Title eighteen, subsection G, paragraph one remains valid and enforceable against convicted felons despite recent Supreme Court jurisprudence.