The U.S. Court of Appeals for the Eleventh Circuit affirmed the federal gun conviction and 105-month prison sentence of Randall Demetrius Broaden, rejecting his constitutional challenge to federal firearm laws in a per curiam opinion filed Jan. 8, 2026.
Broaden appealed his conviction for possession of a firearm as a felon under 18 U.S.C. § 922(g)(1), arguing the district court erred by denying his motion to dismiss the indictment. The three-judge panel consisting of Circuit Judges Abudu, Anderson, and Hull unanimously rejected his appeal.
The case originated from a domestic violence investigation in March 2023. According to court records, Jessica Lawrence reported to police that she had been in an abusive relationship with Broaden for approximately two to three months. Lawrence told authorities that Broaden had threatened her with physical violence and prevented her from leaving the relationship.
The situation escalated on Feb. 27, 2023, when Lawrence reported that Broaden became angry and slapped her. This domestic violence report led police to discover that Broaden was illegally possessing a firearm despite his status as a convicted felon.
Broaden was subsequently charged in the U.S. District Court for the Middle District of Alabama under federal gun control statutes that prohibit convicted felons from possessing firearms. The case was assigned docket number 1:23-cr-00355-ECM-KFP-1.
At the district court level, Broaden moved to dismiss the indictment, apparently challenging the constitutionality of the federal statute under which he was charged. The district court denied this motion and proceeded with the prosecution.
Following his conviction, Broaden received a 105-month federal prison sentence. He then appealed both his conviction and sentence to the Eleventh Circuit, raising constitutional and sentencing challenges.
In its opinion, the appeals court addressed Broaden's constitutional challenge to 18 U.S.C. § 922(g)(1), the federal statute that prohibits convicted felons from possessing firearms. The court wrote that "this Court's binding precedent holds that 18 U.S.C. § 922(g)(1) is constitutional," effectively ending Broaden's constitutional challenge.
The Eleventh Circuit's ruling reflects the circuit's established position on federal gun laws targeting convicted felons. Circuit precedent has consistently upheld the constitutionality of Section 922(g)(1), which forms a cornerstone of federal efforts to prevent gun violence by keeping firearms away from individuals with criminal histories.
Regarding Broaden's sentence, the appeals court conducted both procedural and substantive reasonableness review. The court concluded that "Broaden fails to show that the district court's sentence was procedurally or substantively unreasonable." This indicates the district court properly calculated the sentence under federal sentencing guidelines and that the 105-month term was within acceptable bounds given Broaden's criminal history and the nature of his offense.
The 105-month sentence, equivalent to approximately 8 years and 9 months, reflects the serious nature of federal gun crimes involving convicted felons. Federal sentencing guidelines typically impose enhanced penalties on individuals with prior criminal convictions who illegally possess firearms.
The case was handled through the Eleventh Circuit's non-argument calendar, meaning the court decided the appeal based on written briefs without oral argument. This procedural path is common for appeals where the legal issues are well-settled or the outcome is clear based on existing precedent.
The appeals court's decision represents another affirmation of federal gun control laws in the post-Heller era. While the Supreme Court's decision in District of Columbia v. Heller (2008) established an individual right to bear arms, courts have consistently held that this right does not extend to convicted felons.
The opinion was marked "NOT FOR PUBLICATION," indicating it will not be published in the Federal Reporter and has limited precedential value. However, the decision reinforces established Eleventh Circuit precedent on the constitutionality of federal felon-in-possession statutes.
Broaden's case highlights the intersection of domestic violence investigations and federal gun prosecutions. The discovery of illegal firearm possession often occurs during investigations of other crimes, particularly domestic violence cases where the presence of firearms significantly increases danger to victims.
The Eleventh Circuit's jurisdiction includes Alabama, Florida, and Georgia, and its consistent upholding of federal gun laws affects enforcement throughout the southeastern United States. The court's decision ensures continued federal prosecution of convicted felons found illegally possessing firearms in the region.
With his appeal exhausted at the circuit level, Broaden would need to petition the Supreme Court for certiorari to pursue further appeals, though such petitions are rarely granted in routine gun possession cases involving established legal principles.