Darius Deontae Little entered a conditional guilty plea to possession of a firearm by a convicted felon, violating 18 U.S.C. §§ 922(g)(1) and 924(a)(8). He was sentenced to 24 months of imprisonment followed by three years of supervised release. Little reserved his right to appeal the denial of his motion to dismiss the indictment, arguing that the statute was unconstitutional under the Second Amendment. His challenge relied on the Supreme Court's decisions in New York State Rifle & Pistol Ass'n v. Bruen and United States v. Rahimi, asserting that the statute lacked historical support and that his specific conduct as a nonviolent offender should be protected.
The Fourth Circuit reviewed the constitutional claims de novo but emphasized that a panel is bound by prior circuit precedent unless overruled by an en banc decision or the Supreme Court. In addressing the facial challenge, the court noted that Little's reliance on Rahimi was misplaced because the Fourth Circuit had already reaffirmed in United States v. Canada that § 922(g)(1) is facially constitutional and consistent with Rahimi. Regarding the as-applied challenge, the court pointed to United States v. Hunt, which held that neither Bruen nor Rahimi abrogates the circuit's precedent foreclosing as-applied challenges to § 922(g)(1). The court further reasoned that the statute would pass constitutional muster even without the constraint of circuit precedent, as historical traditions support disarming convicted felons.
The decision reaffirms the constitutionality of 18 U.S.C. § 922(g)(1) within the Fourth Circuit, closing the door on both facial and as-applied Second Amendment challenges by convicted felons. It confirms that lower courts must follow binding circuit precedent from United States v. Canada and United States v. Hunt, even in the wake of Supreme Court rulings like Bruen and Rahimi. No remand instructions were issued as the judgment was affirmed.
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