The U.S. Court of Appeals for the Eleventh Circuit affirmed the conviction of Travion Cortez Vanhorn for possession of a firearm as a convicted felon, rejecting his constitutional challenge to the federal statute in a decision filed Feb. 5, 2026.
Vanhorn was convicted under 18 U.S.C. § 922(g)(1), which prohibits individuals with felony convictions from possessing firearms. On appeal, he argued that the district court erred in denying his motion to dismiss the indictment because the statute is unconstitutional both facially and as applied to his specific circumstances.
The case originated from a routine traffic stop in Alabama. Police officers observed Vanhorn operating a vehicle without wearing a seatbelt and initiated the stop. During the encounter, Vanhorn was unable to produce a driver's license and informed officers that his license was suspended. He also disclosed that he was on probation in Walker County, Alabama, for unlawful distribution of a controlled substance.
The situation escalated when officers detected a strong odor of marijuana coming from Vanhorn's vehicle. A records check revealed that Vanhorn had outstanding misdemeanor warrants with the city of Adamsville, Alabama. Officers asked Vanhorn to exit the vehicle, and he voluntarily made statements during the encounter.
The federal felon-in-possession statute, codified at 18 U.S.C. § 922(g)(1), is one of the most frequently prosecuted federal gun crimes. The law makes it illegal for anyone who has been convicted of a crime punishable by imprisonment for more than one year to possess firearms or ammunition. Violations can result in up to 10 years in federal prison.
Vanhorn's constitutional challenge appears to have focused on both facial and as-applied arguments against the statute. A facial challenge argues that a law is unconstitutional in all circumstances, while an as-applied challenge contends that the law is unconstitutional as applied to the specific facts of a particular case.
The Eleventh Circuit's three-judge panel, consisting of Circuit Judges Jill Pryor, Branch, and Lagoa, issued a per curiam opinion affirming the conviction. Per curiam opinions are unsigned decisions that represent the view of the court as a whole rather than being attributed to a specific judge.
The decision comes at a time when federal courts across the country are grappling with constitutional challenges to various firearms laws in the wake of the Supreme Court's decision in *New York State Rifle & Pistol Association v. Bruen* (2022). That ruling established a new framework for analyzing Second Amendment challenges, requiring courts to determine whether firearms regulations are consistent with the nation's historical tradition of firearm regulation.
Since *Bruen*, defendants in felon-in-possession cases have increasingly challenged § 922(g)(1) on Second Amendment grounds, arguing that the statute violates their constitutional right to bear arms. However, most federal appellate courts have continued to uphold the law, finding that prohibiting felons from possessing firearms is consistent with historical practice.
The Northern District of Alabama, where Vanhorn's case originated, covers a significant portion of the state including Birmingham, Huntsville, and surrounding areas. The district court's denial of Vanhorn's motion to dismiss indicates that the trial court found his constitutional arguments unpersuasive at the pre-trial stage.
The Eleventh Circuit's jurisdiction includes Alabama, Florida, and Georgia, and the court's decisions are binding precedent for federal district courts within those states. This ruling adds to the growing body of post-*Bruen* appellate decisions addressing constitutional challenges to federal firearms laws.
The case was designated for the non-argument calendar, meaning the court decided it based on written briefs without oral argument. This designation typically indicates that the court viewed the legal issues as sufficiently settled or straightforward that oral argument would not significantly aid in the decision-making process.
The brief nature of the available record suggests that Vanhorn's constitutional arguments did not present novel legal theories that would require extensive analysis. Federal appellate courts have generally been receptive to established precedent upholding felon-in-possession statutes, even in the current post-*Bruen* legal landscape.
For practitioners defending clients charged under § 922(g)(1), this decision reinforces the continued viability of the federal felon-in-possession statute against broad constitutional challenges. Defense attorneys may need to craft more narrowly tailored arguments or focus on specific factual circumstances that might distinguish their clients' cases.
The ruling also provides guidance for federal prosecutors handling similar cases in the Eleventh Circuit, confirming that facial and as-applied challenges to § 922(g)(1) remain unlikely to succeed absent extraordinary circumstances or novel legal arguments.
Vanhorn's case reflects the ongoing tension between Second Amendment rights and public safety considerations that have shaped firearms jurisprudence in recent years. While the Supreme Court has strengthened individual gun rights, lower courts continue to find that certain categories of prohibited persons, including convicted felons, fall outside the scope of Second Amendment protection.
The decision was marked "not for publication," indicating that while it establishes binding precedent within the circuit, the court did not view it as making a significant contribution to legal doctrine that would warrant formal publication in the federal reporter system.