The U.S. Court of Appeals for the Eleventh Circuit rejected a convicted felon's Second Amendment challenge to federal gun possession laws, affirming the constitutionality of restrictions on firearm ownership for individuals with criminal records.
In *United States v. Will David Parr* (11th Cir. 2026), the appeals court upheld Parr's conviction for possession of a firearm as a convicted felon under 18 U.S.C. § 922(g)(1). The case represents the latest in a series of post-*Bruen* challenges to federal firearms regulations that have largely failed to gain traction in federal appellate courts.
Parr argued on appeal that the district court plainly erred because § 922(g)(1) is unconstitutional both facially and as applied to him under the Second Amendment. His challenge relied heavily on recent Supreme Court decisions that expanded Second Amendment protections, particularly *New York State Rifle & Pistol Ass'n, Inc. v. Bruen* (2022) and *United States v. Rahimi* (2024).
The *Bruen* decision established a new framework for evaluating Second Amendment challenges, requiring courts to determine whether firearms regulations are consistent with the nation's historical tradition of firearm regulation. The Supreme Court's 2024 decision in *Rahimi* further clarified this test while upholding certain restrictions on gun possession for individuals subject to domestic violence restraining orders.
Parr's appeal originated from his conviction in the U.S. District Court for the Northern District of Alabama. The case was heard by Circuit Judges Brasher, Abudu, and Anderson, who issued a per curiam opinion rejecting his constitutional arguments.
After Parr filed his initial brief on appeal, the government moved for summary affirmance, arguing that binding Eleventh Circuit precedent forecloses his Second Amendment challenge. The court's decision to grant summary disposition indicates the panel found Parr's arguments lacked merit under existing legal standards.
The federal statute at issue, 18 U.S.C. § 922(g)(1), prohibits any person who has been convicted of a crime punishable by imprisonment for more than one year from possessing firearms or ammunition. This provision has been a cornerstone of federal gun control efforts, affecting thousands of individuals with felony convictions nationwide.
Despite the Supreme Court's recent emphasis on historical traditions in Second Amendment analysis, federal appellate courts have consistently upheld felon-in-possession laws. Courts have generally found that such restrictions align with longstanding American traditions of disarming individuals deemed dangerous to public safety.
The *Bruen* decision, while expanding gun rights in some contexts, did not eliminate all firearm regulations. The Supreme Court specifically noted that its decision should not cast doubt on "longstanding prohibitions on the carrying of firearms in sensitive places" or laws "forbidding the carrying of dangerous and unusual weapons."
Parr's case reflects a broader pattern of unsuccessful Second Amendment challenges to felon-in-possession statutes following *Bruen*. While the decision opened new avenues for challenging certain gun regulations, it has not provided the sweeping protection for gun rights that some advocates hoped for.
The Eleventh Circuit's decision reinforces the circuit split that has emerged on various Second Amendment issues in the post-*Bruen* era. While courts have struck down some gun regulations as inconsistent with historical traditions, restrictions on firearm possession by convicted felons have proven more durable.
Legal experts note that the historical record strongly supports the constitutionality of felon-in-possession laws. Colonial and early American legal traditions included various disarmament provisions for individuals who posed threats to public safety, providing the historical foundation that courts now require under the *Bruen* framework.
The case was designated "NOT FOR PUBLICATION," indicating the court viewed the issues as settled law that did not require a precedential opinion. Such designations are common when appellate courts apply well-established legal principles to routine appeals.
For Parr, the decision likely exhausts his direct appeal options unless he seeks Supreme Court review through a petition for certiorari. However, the high court rarely grants review in cases involving straightforward applications of established Second Amendment doctrine.
The ruling maintains the status quo for federal firearms enforcement in the Eleventh Circuit, which covers Alabama, Florida, and Georgia. Federal prosecutors in these states can continue to rely on § 922(g)(1) as a key tool for removing guns from the hands of convicted felons.
As courts continue to grapple with the implications of *Bruen* and *Rahimi*, the Eleventh Circuit's decision in *Parr* demonstrates that core federal gun restrictions retain strong constitutional footing despite evolving Second Amendment jurisprudence. The case underscores that while the Supreme Court has expanded gun rights in certain contexts, longstanding prohibitions on firearm possession by convicted felons remain firmly established in American law.