The U.S. Court of Appeals for the Eleventh Circuit is reviewing a constitutional challenge to federal gun possession laws that could reshape how courts evaluate Second Amendment rights for convicted felons. In *United States v. Dimitri Beaubrun*, the defendant appeals his conviction for possessing a firearm and ammunition as a convicted felon, arguing that the federal statute violates his constitutional rights.
Beaubrun was convicted under 18 U.S.C. § 922(g)(1), which prohibits any person who has been convicted of a felony from possessing firearms or ammunition. The case originated in the U.S. District Court for the Southern District of Florida and is now before a three-judge panel consisting of Circuit Judges Jill Pryor, Branch, and Lagoa.
The central legal question involves whether the federal felon-in-possession statute violates the Second Amendment as applied to individuals with nonviolent criminal histories. Beaubrun specifically argues that the blanket prohibition fails to account for the nature and circumstances of different felony convictions, creating an unconstitutional burden on his right to bear arms.
The appeal centers on apparent tensions between recent Eleventh Circuit decisions. Beaubrun contends that the court's 2025 decision in *United States v. Dubois* (*Dubois II*), 139 F.4th 887 (11th Cir. 2025), conflicts with the circuit's en banc ruling in *NRA v. Bondi*, 133 F.4th 1108 (11th Cir. 2025). The *Dubois II* decision reaffirmed the circuit's earlier holding in *United States v. Rozier*, 598 F.3d 768 (11th Cir. 2010), which found that § 922(g)(1) does not violate the Second Amendment.
However, Beaubrun argues that the *Bondi* decision, decided by the full circuit court sitting en banc, established different constitutional standards that should apply to his case. En banc decisions carry greater precedential weight than three-judge panel decisions, potentially creating uncertainty about how the circuit should analyze Second Amendment challenges to felon-in-possession laws.
The case reflects broader national debates about gun rights following the Supreme Court's transformative Second Amendment jurisprudence. Recent Supreme Court decisions have emphasized that the Second Amendment protects an individual right to keep and bear arms, leading lower courts to reconsider various firearms regulations that were previously considered settled law.
Federal law currently imposes lifetime prohibitions on firearm possession for anyone convicted of a felony, regardless of the nature of the underlying offense or the time elapsed since conviction. This blanket approach has faced increasing legal challenges, particularly from individuals convicted of nonviolent offenses who argue their circumstances do not justify permanent loss of constitutional rights.
The distinction between violent and nonviolent felonies has become increasingly important in Second Amendment litigation. Critics of current law argue that someone convicted of a nonviolent financial crime or drug offense should not face the same firearms restrictions as someone convicted of violent assault or armed robbery.
Beaubrun's case could establish important precedent for how the Eleventh Circuit evaluates as-applied challenges to federal gun laws. An as-applied challenge argues that while a law might be constitutional in general, it violates constitutional rights when applied to specific circumstances or individuals.
The circuit court must navigate complex questions about the historical understanding of Second Amendment rights and how those principles apply to modern firearms regulations. Courts increasingly examine whether contemporary gun laws are consistent with historical traditions of firearm regulation that existed when the Second Amendment was ratified.
The outcome could significantly impact federal prosecutions throughout the Eleventh Circuit, which covers Alabama, Florida, and Georgia. If the court finds that § 922(g)(1) cannot be constitutionally applied to certain categories of nonviolent felons, it could limit prosecutors' ability to bring felon-in-possession charges in those cases.
The case also highlights ongoing tensions between public safety concerns and constitutional rights. Supporters of current law argue that felon-in-possession statutes serve important crime prevention purposes, while critics contend that blanket prohibitions sweep too broadly and fail to account for individual circumstances.
The Eleventh Circuit's decision will join a growing body of federal appellate court rulings examining Second Amendment challenges to various gun regulations. Different circuits have reached varying conclusions about similar constitutional questions, potentially setting up future Supreme Court review.
Given the case's designation for the non-argument calendar, the court will likely decide the matter based solely on written briefs without oral arguments. This procedural approach suggests the panel may view the legal issues as sufficiently clear-cut, though the constitutional questions at stake remain complex and consequential.
The resolution of Beaubrun's appeal could clarify how the Eleventh Circuit will balance Second Amendment rights against public safety concerns in future cases involving firearms restrictions for convicted felons.