The U.S. Court of Appeals for the Eleventh Circuit has affirmed a federal conviction for felon-in-possession of a firearm, rejecting constitutional challenges to the longstanding federal prohibition on gun ownership by convicted felons.
In *United States v. Ro'Daryus Mitchell* (11th Cir. 2026), the appeals court granted the government's motion for summary affirmance, upholding Mitchell's conviction under 18 U.S.C. § 922(g)(1). The decision reinforces the circuit's position that federal felon-in-possession statutes remain constitutional despite recent Supreme Court precedent expanding Second Amendment protections.
Mitchell was arrested in May 2023 at his girlfriend's apartment on outstanding warrants when law enforcement officers discovered firearms inside the residence. Given his previous felony convictions, Mitchell was charged with being a felon in possession of a firearm under the federal statute that prohibits individuals with felony records from possessing firearms.
The defendant mounted a comprehensive constitutional challenge to the federal law, arguing that 18 U.S.C. § 922(g)(1) violated his Second Amendment rights both facially and as applied to his specific circumstances. Mitchell's facial challenge contended that the entire statutory scheme prohibiting felons from possessing firearms was unconstitutional under current Second Amendment jurisprudence. His as-applied challenge argued that the law's application to his particular case violated his constitutional rights.
The U.S. District Court for the Northern District of Alabama initially denied Mitchell's motion to dismiss the indictment. Following this ruling, Mitchell entered a guilty plea while strategically reserving his right to appeal the constitutional questions. This procedural move allowed him to accept responsibility for the underlying conduct while preserving his ability to challenge the law's validity on constitutional grounds.
The case comes amid ongoing national debate over the scope of Second Amendment protections, particularly following recent Supreme Court decisions that have expanded gun rights. The high court's decision in *New York State Rifle & Pistol Association v. Bruen* (2022) established a new framework for evaluating Second Amendment challenges, requiring courts to assess whether modern gun regulations are consistent with the nation's historical tradition of firearms regulation.
This historical test has created uncertainty about the continued validity of various federal gun laws, including felon-in-possession statutes that have been a cornerstone of federal firearms enforcement for decades. Lower courts have struggled to apply the *Bruen* framework to longstanding regulations, leading to a patchwork of decisions on similar constitutional challenges.
The Eleventh Circuit's summary affirmance suggests the court found Mitchell's constitutional arguments lacked merit and that existing circuit precedent adequately resolved the legal questions presented. Summary affirmance is a procedural tool that allows appeals courts to affirm lower court decisions without full briefing or oral argument when the legal issues are clearly resolved by existing precedent or the appeal lacks substantial merit.
The decision affects residents across the Eleventh Circuit's jurisdiction, which encompasses Alabama, Florida, and Georgia. Federal prosecutors in these states continue to rely heavily on felon-in-possession charges as a tool for addressing gun violence, particularly in cases involving repeat offenders and individuals with violent criminal histories.
Mitchell's case reflects a broader pattern of constitutional challenges to federal gun laws following the Supreme Court's expansion of Second Amendment protections. Defense attorneys across the country have filed similar challenges to 18 U.S.C. § 922(g)(1), with mixed results in different federal circuits. Some courts have found that historical evidence supports disarming felons, while others have expressed skepticism about applying colonial-era precedents to modern criminal justice systems.
The constitutional questions surrounding felon-in-possession laws remain unsettled at the national level. While most federal circuits have upheld these statutes against Second Amendment challenges, the variation in reasoning and analysis has created potential grounds for Supreme Court review. Legal scholars continue to debate whether the historical record supports broad categorical disarmament of all individuals with felony convictions, regardless of the nature of their underlying offenses.
For federal prosecutors, the Eleventh Circuit's decision provides continued support for using felon-in-possession charges as a prosecutorial tool. These cases often serve as the foundation for broader criminal justice strategies targeting repeat offenders and individuals involved in firearms trafficking. The statute carries significant penalties, including up to 10 years in federal prison for violations.
The case also highlights ongoing tensions between public safety concerns and individual constitutional rights in the firearms context. Supporters of felon-in-possession laws argue they serve essential public safety functions by keeping weapons away from individuals with demonstrated propensities for criminal behavior. Critics contend that permanent disarmament of all felons, regardless of the nature or age of their convictions, may exceed constitutional bounds.
Mitchell's conviction stands affirmed, and the Eleventh Circuit's summary disposition suggests the court views the constitutional questions as clearly resolved under existing precedent. The decision contributes to the growing body of post-*Bruen* jurisprudence addressing the scope of Second Amendment protections and the validity of longstanding federal firearms regulations.