The Fourth Circuit Court of Appeals affirmed the conviction of Daniel Earl Logan for illegal possession of firearms and ammunition by a convicted felon, rejecting his constitutional challenge in an unpublished per curiam opinion issued January 8, 2026.
Logan was charged under 18 U.S.C. § 922(g)(1), which prohibits convicted felons from possessing firearms or ammunition. The case originated in the U.S. District Court for the Western District of North Carolina at Asheville, where District Judge Max O. Cogburn Jr. presided over the proceedings.
In a notable legal strategy, Logan attempted to dismiss the federal indictment by arguing that Section 922(g)(1) violates the Second Amendment. His motion relied heavily on the Supreme Court's decision in New York State Rifle & Pistol Association v. Bruen (2022), which established that firearm regulations are constitutional only if they are "consistent with this Nation's historical tradition of firearm regulation."
The Bruen standard has emerged as a significant test for federal gun laws since the Supreme Court's ruling in 2022. The decision requires courts to examine whether modern firearms regulations have historical analogues dating to the founding era or the period surrounding the ratification of the Fourteenth Amendment. This test has created new challenges for prosecutors defending federal gun statutes and new opportunities for defendants to challenge longstanding prohibitions.
Logan's constitutional challenge represents part of a broader wave of Second Amendment litigation following Bruen. Defense attorneys across the country have invoked the decision to challenge various federal firearms laws, particularly those targeting prohibited persons such as convicted felons. The cases have produced mixed results in federal courts, with some judges finding that historical precedent supports felon-in-possession laws while others have questioned their constitutional foundation.
The district court denied Logan's motion to dismiss the indictment, finding that Section 922(g)(1) withstands constitutional scrutiny under the Bruen standard. Following this ruling, Logan entered a guilty plea to the charges and received sentencing from the district court. The specific sentence imposed was not detailed in the available court documents.
Logan's legal representation came from the Federal Public Defender's Office, with John G. Baker serving as Federal Public Defender and Assistant Federal Public Defender Ashley A. Askari handling the case. The government's case was prosecuted by Assistant U.S. Attorney Amy Elizabeth Ray from the Asheville office.
The Fourth Circuit's decision to affirm the conviction came through a three-judge panel consisting of Circuit Judges J. Harvie Wilkinson III and Pamela A. Harris, along with Senior Circuit Judge Barbara Milano Keenan. The court's ruling was issued as an unpublished per curiam opinion, meaning it was decided unanimously without a single judge authoring the decision.
Unpublished opinions, while not binding precedent within the Fourth Circuit, still provide guidance on how appellate courts are interpreting post-Bruen challenges to federal gun laws. The Fourth Circuit's decision suggests that courts continue to find constitutional support for laws prohibiting firearm possession by convicted felons, even under the heightened scrutiny required by Bruen.
The case reflects ongoing enforcement priorities within the federal criminal justice system regarding firearms violations. Felon-in-possession prosecutions remain a cornerstone of federal gun crime enforcement, with U.S. attorneys' offices across the country regularly pursuing such cases under Section 922(g)(1).
The constitutional questions surrounding felon-in-possession laws have created uncertainty in some jurisdictions, but the Fourth Circuit's affirmance suggests these challenges face significant hurdles. Courts have generally found historical precedent supporting the disarmament of certain categories of persons, including those convicted of serious crimes.
Logan's case proceeded through the standard appellate timeline, with the case submitted to the Fourth Circuit on December 19, 2025, and decided less than three weeks later on January 8, 2026. This relatively quick turnaround suggests the court found the constitutional issues sufficiently settled to warrant expedited resolution.
The broader implications of the decision extend beyond Logan's individual case. As federal courts continue to grapple with the scope and application of the Bruen standard, decisions like this one help establish patterns in how appellate courts view Second Amendment challenges to established federal firearms laws.
The case number 24-4421 in the Fourth Circuit stems from the original district court case 1:23-cr-00074-MOC-WCM-1, indicating the case began in 2023 and proceeded through the federal court system over approximately two years before reaching its appellate conclusion.
While Logan's appeal was unsuccessful, the case represents part of the ongoing judicial interpretation of Second Amendment rights in the post-Bruen legal landscape, where courts must balance individual constitutional rights against established public safety regulations targeting prohibited persons.