Ryan Carl Lowmaster pleaded guilty to one count of being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) and was sentenced to 84 months in prison followed by three years of supervised release. On appeal, Lowmaster argued that the federal statute prohibiting felons from possessing firearms is unconstitutional under the Second Amendment, both on its face and as applied to him. However, he explicitly noted in his brief that this argument was being raised for preservation purposes only because it was currently foreclosed by the Tenth Circuit's prior decision in Vincent v. Garland. This procedural posture meant the court did not need to engage in a deep factual analysis of his specific circumstances, but rather had to address the controlling legal precedent.
The panel unanimously determined that the case could be decided without oral argument and proceeded to affirm the district court's judgment. The core of the court's reasoning rests on the doctrine of binding precedent. Lowmaster's Second Amendment challenge was rejected because the issue was 'foreclosed by Vincent v. Garland, 80 F.4th 1197 (10th Cir. 2023).' The court noted a complex procedural history: after Lowmaster filed his brief, the Supreme Court vacated the Vincent decision and remanded it for reconsideration in light of United States v. Rahimi. However, the Tenth Circuit subsequently readopted its original decision in Vincent v. Bondi, 127 F.4th 1263 (10th Cir. 2025), and the Supreme Court denied certiorari on that readoption on March 2, 2026. Consequently, Vincent v. Garland remains the controlling authority in the Tenth Circuit. The court also noted that while Lowmaster did not raise the claim below, he could not show plain error because his own brief admitted the issue was foreclosed by circuit precedent.
This decision confirms that within the Tenth Circuit, the prohibition on felons possessing firearms under 18 U.S.C. § 922(g)(1) remains constitutionally valid despite the Supreme Court's recent ruling in United States v. Rahimi. The practical effect is that defendants in the Tenth Circuit cannot successfully challenge this statute on Second Amendment grounds unless the Supreme Court grants certiorari on a future case or the Tenth Circuit explicitly overrules Vincent v. Garland. The case is closed, and the conviction and sentence stand.
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