The U.S. Court of Appeals for the Fourth Circuit affirmed the conviction and sentencing of Frederick Siou Beaufort for illegal firearm possession by a convicted felon, rejecting his constitutional challenge based on the Supreme Court's 2022 Second Amendment decision in *New York State Rifle & Pistol Ass'n v. Bruen*.
The three-judge panel issued an unpublished per curiam opinion on Jan. 26, 2026, upholding the U.S. District Court for the District of South Carolina's decision. Circuit Judges Agee, Richardson, and Heytens heard the appeal, which was submitted Jan. 22 and decided four days later.
Beaufort pleaded guilty to possession of a firearm and ammunition by a convicted felon, in violation of 18 U.S.C. § 922(g)(1). District Judge Mary G. Lewis sentenced him to 27 months' imprisonment, which fell on the lower end of his Sentencing Guidelines range.
On appeal, Beaufort argued that § 922(g)(1) is both facially unconstitutional and unconstitutional as applied to him following the Supreme Court's decision in *Bruen*. In that case, the Supreme Court held that a firearm regulation is valid under the Second Amendment only if it "is consistent with this Nation's historical tradition of firearm regulation."
The Supreme Court's decision in *Bruen* (597 U.S. 1, 17 (2022)) established a new framework for evaluating Second Amendment challenges to firearm regulations. The court rejected the intermediate scrutiny test that many circuits had been using and instead required that gun laws be grounded in the nation's historical tradition of firearm regulation.
Beaufort's challenge represents part of a wave of constitutional attacks on federal firearm laws following *Bruen*. Defense attorneys across the country have argued that various gun restrictions, including prohibitions on firearm possession by convicted felons, cannot satisfy the Supreme Court's new historical test.
The federal law at issue, 18 U.S.C. § 922(g)(1), makes it illegal for anyone who has been convicted of a crime punishable by imprisonment for more than one year to possess firearms or ammunition. This provision has been a cornerstone of federal gun enforcement for decades and affects hundreds of thousands of people with felony convictions.
While the Fourth Circuit's opinion was unpublished and therefore not binding precedent within the circuit, it adds to the growing body of post-*Bruen* case law addressing challenges to felon-in-possession laws. Courts across the country have reached varying conclusions about whether such restrictions can survive constitutional scrutiny under the new historical test.
Some federal appellate courts have found that historical analogues support prohibiting firearm possession by certain categories of people deemed dangerous, including those with serious criminal convictions. Others have been more skeptical, particularly regarding non-violent felonies or very old convictions.
Beaufort was represented by Taylor D. Gilliam, an Assistant Federal Public Defender from Columbia, South Carolina. The government was represented by U.S. Attorney Bryan P. Stirling and Assistant U.S. Attorney Andrea G. Hoffman from the Charleston office.
The case originated in the District of South Carolina at Columbia, where Beaufort entered his guilty plea in 2024. The criminal case number was 3:24-cr-00406-MGL-1, indicating it was filed under the court's 2024 docket.
The swift resolution of the appeal—decided just four days after submission—suggests the Fourth Circuit panel found Beaufort's constitutional arguments unpersuasive. The court's decision to issue an unpublished per curiam opinion, rather than a signed opinion by an individual judge, typically indicates the panel viewed the legal issues as relatively straightforward.
Felon-in-possession cases make up a significant portion of federal criminal prosecutions. The Bureau of Alcohol, Tobacco, Firearms and Explosives prioritizes enforcement of § 922(g)(1), and federal prosecutors frequently use the statute to target individuals with criminal histories who are found with firearms during other law enforcement activities.
The sentence of 27 months imprisonment that Beaufort received falls within the typical range for such violations, though sentences can vary significantly based on factors including the defendant's criminal history, the type of firearm involved, and whether the violation occurred in connection with other crimes.
Beaufort's case demonstrates the continued viability of federal felon-in-possession prosecutions even after *Bruen*. While the Supreme Court's decision has complicated the legal landscape for firearms regulations, it has not eliminated the government's ability to prohibit gun possession by individuals with serious criminal convictions.
The Fourth Circuit's jurisdiction includes Maryland, Virginia, West Virginia, North Carolina, and South Carolina. The court's handling of Second Amendment challenges will likely influence how district courts within these states approach similar cases going forward, even though this particular decision carries no precedential weight.
As courts continue to grapple with the implications of *Bruen*, cases like *United States v. Beaufort* provide insight into how appellate panels are applying the Supreme Court's historical methodology to longstanding federal firearms restrictions.