The U.S. Court of Appeals for the Third Circuit affirmed both the conviction and 100-month prison sentence of Victorious Minter for unlawfully possessing a firearm as a convicted felon, following a January 2022 road rage incident in Scranton, Pennsylvania.
Circuit Judge Jane Roth, writing for a three-judge panel that included Judges Phipps and Chung, issued the precedential opinion on Jan. 16, 2026. The court held that a recent Supreme Court ruling foreclosed Minter's "only colorable argument on appeal," leading to the unanimous affirmation of both his conviction and sentence.
The incident that led to Minter's conviction occurred on Jan. 5, 2022, when Scranton police received a report that a man matching Minter's description had brandished a gun at another driver during a road rage incident. Officers subsequently pulled over Minter, who was driving with his partner and infant son, and discovered a loaded Glock .22 semi-automatic pistol in plain view inside the vehicle.
Minter's criminal history proved crucial to the case. At the time of his arrest, he had numerous prior felony convictions and remained on state parole for one of those convictions. This criminal background made his possession of the firearm illegal under federal law.
Federal prosecutors charged Minter with unlawful possession of a firearm by a felon, in violation of 18 U.S.C. § 922(g)(1). Following a trial in the U.S. District Court for the Middle District of Pennsylvania, a jury convicted Minter on the charge.
During sentencing proceedings before District Judge Robert D. Mariani, the court calculated Minter's guidelines offense level at 30 and his criminal history category at 4. These calculations yielded an effective guidelines sentence range that supported a 120-month prison term. However, Judge Mariani imposed a below-guidelines sentence of 100 months' incarceration.
Minter appealed his conviction and sentence to the Third Circuit, represented by federal public defender Elliot A. Smith. The government was represented by federal prosecutors Christian T. Haugsby and Carlo D. Marchioli from the U.S. Attorney's Office for the Middle District of Pennsylvania.
The appeals court's opinion, while brief in the excerpted portion available, indicates that Minter's appeal centered on what the court characterized as his "only colorable argument." However, the Third Circuit determined that a recent Supreme Court ruling had effectively eliminated the viability of this argument, leaving no grounds for reversing either the conviction or the sentence.
The case was submitted to the appeals court under Third Circuit Local Appellate Rule 34.1(a) on May 22, 2025, suggesting it was decided without oral argument based on the briefs and record alone. This procedural posture is common in cases where the legal issues are considered straightforward or where recent precedent clearly resolves the questions presented.
The Third Circuit's decision represents another application of federal felon-in-possession laws, which prohibit individuals with felony convictions from possessing firearms. These prosecutions have become increasingly common as federal authorities focus on reducing gun violence by targeting repeat offenders who illegally possess weapons.
The 100-month sentence imposed by the district court reflects the serious nature of the offense and Minter's extensive criminal history. Federal sentencing guidelines typically result in substantial prison terms for defendants with multiple prior felony convictions who are found to illegally possess firearms.
The road rage context of Minter's arrest adds another dimension to the case, highlighting how traffic incidents can escalate into serious federal criminal charges when firearms are involved. The fact that Minter was traveling with his partner and infant son when arrested underscores the potential danger posed by the combination of road rage and illegal weapon possession.
The appeals court's characterization of the case as having only one "colorable argument" suggests that Minter's legal team faced significant challenges in mounting an effective appeal. The reference to a recent Supreme Court ruling that "forecloses" this argument indicates that changes in federal jurisprudence worked against Minter's position.
This precedential decision by the Third Circuit will likely influence future cases involving similar fact patterns within the court's jurisdiction, which covers Pennsylvania, New Jersey, Delaware, and the Virgin Islands. The opinion reinforces the federal courts' commitment to enforcing felon-in-possession laws, particularly in cases involving public safety risks like road rage incidents.
The affirmation of Minter's conviction and sentence demonstrates the federal judiciary's continued support for prosecuting prohibited persons who unlawfully possess firearms, regardless of the circumstances of their arrest or the arguments raised on appeal.