The U.S. Court of Appeals for the Fourth Circuit affirmed the criminal conviction of James Gould on Jan. 2, 2026, rejecting his constitutional challenge to federal laws that prohibit firearm possession by individuals who have been involuntarily committed to mental health institutions. The three-judge panel's published opinion represents a significant ruling on Second Amendment protections in the context of mental health restrictions on gun ownership.

Gould pleaded guilty to violating 18 U.S.C. § 922(g)(4), which makes it a federal crime for anyone who has been involuntarily committed to a mental institution to possess firearms or ammunition. The case originated from a February 2022 incident when police discovered Gould in his West Virginia home in possession of a twelve-gauge shotgun.

According to court documents, Gould had been involuntarily committed to mental health facilities on four separate occasions between May 2016 and July 2019. Despite this history, he was found in possession of the firearm, leading to federal charges.

In his appeal, Gould challenged the constitutionality of 18 U.S.C. § 922(g)(4) under the Second Amendment, arguing that the prohibition violated his fundamental right to keep and bear arms. The Fourth Circuit panel applied the Supreme Court's framework from New York State Rifle & Pistol Association v. Bruen, which requires courts to examine whether firearms regulations are consistent with the nation's historical tradition of firearm regulation.

The court found that prohibitions on firearm possession by individuals with mental health commitments have deep historical roots in American law, dating back to colonial and early state regulations. The panel concluded that such restrictions fall within the scope of permissible regulations that do not violate the Second Amendment's core protections.

The published decision provides important precedent for how courts should evaluate mental health-based firearm restrictions under the post-Bruen constitutional analysis. Legal experts note that the ruling reinforces the principle that certain categories of individuals may be constitutionally excluded from Second Amendment protections based on historical regulatory traditions.