Background
Rodzebies Smith appealed his conviction for possessing a firearm as a felon, arguing that the statute violated the Second Amendment. The government moved for summary affirmance, citing binding Eleventh Circuit precedent.
The court’s reasoning
The court reviewed the constitutionality of the statute de novo and applied the rule that prior panel holdings are binding unless overruled or undermined by the Supreme Court. The court explained that while Bruen and Rahimi established a history-and-tradition test, they did not abrogate the earlier decision in United States v. Rozier. The court found that the decision in United States v. Dubois, which reaffirmed Rozier, did not conflict with the general rule in National Rifle Association v. Bondi. Consequently, the court held that Dubois and Rozier continued to bar Second Amendment challenges to the statute.
Because the government’s position is clearly right as a matter of law, we grant its motion and affirm.
USCA11 Case: 25-14423 Document: 23-1 Date Filed: 07/06/2026 Page: 1 of 6
What it means going forward
The ruling reinforces that the Eleventh Circuit’s precedent prohibiting felons from possessing firearms remains valid and binding despite subsequent Supreme Court guidance on historical analysis.