Jaterron Williamson appealed his conviction for possessing a firearm as a convicted felon. He argued that the federal statute prohibiting such possession was unconstitutional as applied to him because his prior felony convictions were not analogous to colonial-era offenses punishable by death or estate forfeiture, and that the law exceeded Congress's power under the Commerce Clause. The government filed a motion for summary affirmance, arguing the appeal could be resolved without further briefing. The district court had previously rejected Williamson's Second Amendment challenge based on pre-Bruen caselaw, but Williamson sought a remand to apply the correct post-Bruen framework.
The court denied the government's motion for summary affirmance, noting that while the appeal could be resolved without briefing, summary affirmance is not appropriate under Fifth Circuit precedent. On the merits, the court addressed Williamson's two constitutional challenges. First, regarding the Second Amendment, the court found that Williamson's as-applied challenge was foreclosed by binding precedent. Williamson had three prior felony convictions for 'Deadly Conduct – Discharge Firearm at Individual.' The court determined these offenses were closely analogous to the deadly conduct conviction relied upon in United States v. Reyes to reject a similar as-applied challenge. The court emphasized that a panel of this court cannot overturn another panel's decision absent an intervening change in the law. Second, the court noted that Williamson correctly conceded his Commerce Clause challenge was foreclosed by United States v. Alcantar. A concurring opinion by Judge Willett, joined by Judge Wilson, agreed with the result but expressed doubt about the correctness of precedent rejecting enumerated-powers challenges and noted mixed signals in the circuit regarding the proper framework for as-applied Second Amendment challenges.
The judgment of the district court is affirmed, meaning Williamson's conviction stands. The decision reinforces the binding nature of the Fifth Circuit's prior rulings in United States v. Reyes and United States v. Diaz regarding firearm possession by convicted felons. While the court declined to grant summary affirmance, it resolved the appeal on the merits, leaving no open questions for the district court on remand. However, Judge Willett's concurrence highlights ongoing doctrinal uncertainty regarding the Commerce Clause basis for the statute and the specific historical test for as-applied challenges, suggesting these issues may require future clarification by the full court or the Supreme Court.
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