The U.S. Court of Appeals for the Fourth Circuit issued a published opinion Tuesday partially reversing a district court's dismissal of federal firearms charges against James William Jacobs, in a case that highlights ongoing constitutional challenges to gun laws following recent Supreme Court decisions.
In United States v. James William Jacobs, a three-judge panel unanimously reversed in part, vacated in part, and remanded the case to the U.S. District Court for the Northern District of West Virginia. Judge Andre Agee wrote the opinion, joined by Judges Richardson and Benjamin.
Jacobs was indicted in 2023 for allegedly violating 18 U.S.C. §§ 922(g)(1) and 922(g)(9), federal statutes that prohibit certain individuals from possessing firearms. Section 922(g)(1) bars convicted felons from possessing guns, while section 922(g)(9) prohibits individuals convicted of domestic violence offenses from firearm possession.
The district court had applied the Supreme Court's test established in New York State Rifle & Pistol Association v. Bruen to examine whether these federal prohibitions violated the Second Amendment as applied to Jacobs' specific circumstances. Following the Bruen framework, which requires historical analysis of firearm regulations, the lower court found the statutes unconstitutional as applied to the defendant.
The Fourth Circuit's partial reversal creates binding precedent across the circuit's jurisdiction, which encompasses Maryland, Virginia, West Virginia, North Carolina, and South Carolina. The decision reflects the ongoing challenges federal courts face in applying evolving Second Amendment jurisprudence to longstanding federal firearms laws.
The case returns to the district court for further proceedings consistent with the appellate court's ruling.
