The U.S. Court of Appeals for the Third Circuit issued a non-precedential opinion Tuesday affirming a federal firearms conviction and rejecting Second Amendment challenges to the underlying statute. In *United States v. Dijuan Taylor*, the appeals court upheld the defendant's sentence for violating federal gun possession laws.
Taylor appealed his conviction under 18 U.S.C. § 922(g)(1), which prohibits certain categories of individuals from possessing firearms. The statute applies to anyone who has been convicted of a felony punishable by imprisonment exceeding one year, among other prohibited categories. Taylor challenged the law on constitutional grounds, arguing it violated the Second Amendment both on its face and as applied to his specific circumstances.
The case originated in the U.S. District Court for the Western District of Pennsylvania, where District Judge Nora B. Fischer presided over the criminal proceedings. Taylor was indicted in 2023 and subsequently convicted of the federal firearms violation. Court records indicate Taylor was on state probation at the time of his federal indictment, a detail that proved significant to the appellate court's analysis.
In his appeal to the Third Circuit, Taylor mounted a constitutional challenge arguing that Section 922(g)(1) infringed upon his Second Amendment right to keep and bear arms. He contended the federal statute was unconstitutional both facially - meaning the law itself is invalid - and as applied to his particular situation. Such constitutional challenges have become increasingly common in federal firearms cases following recent Supreme Court decisions that have strengthened Second Amendment protections.
However, Taylor's legal team acknowledged a significant procedural hurdle: existing Third Circuit precedent directly contradicted their arguments. Specifically, Taylor conceded that his constitutional challenges were "foreclosed" by two prior Third Circuit decisions - *United States v. Moore* and *United States v. Quailes*. Both cases involved defendants who, like Taylor, were on state probation when charged with federal firearms violations.
The Third Circuit panel, consisting of Circuit Judges Restrepo, McKee, and Ambro, agreed with this assessment. Judge McKee authored the brief opinion, noting that Taylor's probationary status at the time of his indictment brought his case squarely within the precedent established by *Moore* and *Quailes*. The court applied the doctrine of stare decisis, which requires lower courts to follow established precedent from higher courts within the same jurisdiction.
The appeals court exercised jurisdiction under 28 U.S.C. § 1291, which grants federal appellate courts authority to review final decisions of district courts. The panel applied a de novo standard of review to the district court's legal conclusions while reviewing factual findings for clear error - standard appellate procedure in criminal cases involving constitutional questions.
Taylor's case represents part of a broader trend of constitutional challenges to federal firearms statutes following the Supreme Court's decision in *New York State Rifle & Pistol Association v. Bruen* in 2022. That decision established a new framework for evaluating Second Amendment claims, requiring courts to assess whether gun regulations are consistent with the nation's historical tradition of firearms regulation. However, circuit courts have generally continued to uphold Section 922(g)(1) prohibitions, particularly for individuals with felony convictions or those under criminal justice supervision.
The Third Circuit designated its opinion as "not precedential," meaning it does not establish binding legal precedent for future cases. Such dispositions are common for straightforward appeals where existing precedent clearly controls the outcome. The court noted that the disposition "does not constitute binding precedent" under Internal Operating Procedure 5.7.
Federal firearms prosecutions under Section 922(g)(1) remain a priority for federal prosecutors, particularly in jurisdictions with high rates of gun violence. The Western District of Pennsylvania, which covers Pittsburgh and surrounding areas, has been active in pursuing such cases as part of broader federal crime reduction efforts.
The case was submitted to the appeals court under Third Circuit Local Appellate Rule 34.1(a) in November 2025, with the opinion filed January 7, 2026. This procedural track is typically used for cases deemed suitable for resolution without oral argument.
For Taylor, the affirmance means his federal conviction and sentence remain intact. The decision also reinforces the continued viability of federal firearms prosecutions against individuals with criminal histories, even in the wake of evolving Second Amendment jurisprudence. While defendants continue to challenge Section 922(g)(1) on constitutional grounds, federal courts have largely maintained that the statute's prohibitions on firearm possession by certain categories of individuals remain constitutionally permissible.