Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. RODZEBIES JERMINE SMITH

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-06

Docket: 9:25-cr-80102-DMM-1

The Eleventh Circuit affirmed Rodzebies Smith’s conviction for possessing a firearm as a felon in violation of 18 U.S.C. § 922(g)(1), granting the government’s motion for summary affirmance. The court held that Smith’s Second Amendment challenge to the statute is foreclosed by binding circuit precedent, specifically *United States v. Rozier* and *United States v. Dubois*. Applying the standard of review for summary disposition, the court determined that the government’s position was “clearly right as a matter of law” because no substantial question existed regarding the outcome. The court rejected Smith’s argument that the en banc decision in *National Rifle Association v. Bondi* abrogated prior precedent by requiring a new application of the Supreme Court’s history-and-tradition test from *N.Y. State Rifle & Pistol Ass’n v. Bruen* and *United States v. Rahimi*. The panel reasoned that *Bondi* merely reiterated the general methodology for evaluating Second Amendment challenges without explicitly overruling previous decisions, allowing it to coexist with *Dubois*, which confirmed that *Rozier* remains binding precedent regarding felon-in-possession laws. Consequently, the court found that *Dubois* controls the case and bars Smith’s constitutional challenge. The practical consequence is that the district court’s judgment of conviction stands, and Smith’s sentence remains in effect.

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