Background
Tracy Ranard Grant, Jr. was convicted by a jury in the District of South Carolina of one count of possession of a firearm and ammunition as a convicted felon. The conviction stemmed from an investigation into his illegal possession of a Glock Model twenty-two semi-automatic pistol and ammunition. The district court sentenced him to forty-one months of imprisonment followed by three years of supervised release. Grant appealed, challenging the admission of expert testimony, the sufficiency of the evidence, and the constitutionality of the statute.
The court’s reasoning
The court reviewed the admission of expert testimony for plain error and found the prosecution sufficiently established the expert’s qualifications and the reliability of the testimony. Regarding the sufficiency of evidence, the court determined the record contained substantial proof that Grant possessed the firearm and ammunition. Finally, the court held that the argument that the statute violates the Second Amendment is foreclosed by the Fourth Circuit’s 2024 decision in United States v. Canada.
What it means going forward
The decision reinforces the binding precedent of United States v. Canada regarding felon-in-possession statutes and confirms that evidentiary rulings may be reviewed for plain error when not objected to at trial.