The U.S. Court of Appeals for the Sixth Circuit affirmed the conviction of Tommie Conner for being a felon in possession of a firearm, following a case that began with a routine traffic stop in Memphis in 2021. The court's opinion, filed Jan. 15, 2026, upholds both the conviction and the substantial prison sentence imposed under federal firearms laws.
The case originated on March 4, 2021, when Officer Jacques Roberts of the Memphis Police Department observed Conner's Dodge Durango speeding on a road with a 45-mile-per-hour speed limit. During the traffic stop, officers spotted a gun and magazine inside the vehicle. Upon discovering that Conner was a convicted felon, police obtained a search warrant for the car, recovered the firearm, and arrested him.
A federal jury in the U.S. District Court for the Western District of Tennessee found Conner guilty of violating 18 U.S.C. § 922(g), which prohibits convicted felons from possessing firearms. The jury also determined that Conner qualified for a sentence enhancement under the Armed Career Criminal Act, codified at 18 U.S.C. § 924(e).
The Armed Career Criminal Act imposes a 15-year mandatory minimum sentence on individuals who violate the felon-in-possession statute and have "three previous convictions for a violent felony committed on occasions different from one another." The district court ultimately sentenced Conner to 200 months in prison, which exceeds the mandatory minimum.
The Sixth Circuit panel, consisting of Circuit Judges Clay, Kethledge and Larsen, reviewed Conner's appeal and affirmed the lower court's decision. Judge Clay authored the opinion for the court. The appeals court found no reversible error in the proceedings that led to Conner's conviction and sentence.
The case highlights the intersection of routine traffic enforcement and federal firearms prosecutions. Federal law enforcement agencies frequently rely on local police encounters to identify and prosecute individuals who illegally possess firearms. The felon-in-possession statute is among the most commonly prosecuted federal firearms offenses.
Under 18 U.S.C. § 922(g), it is unlawful for any person who has been convicted of a crime punishable by imprisonment for more than one year to possess firearms or ammunition. The statute applies regardless of whether the prior conviction occurred in state or federal court, and violations can result in up to 10 years in prison for first-time offenders.
The Armed Career Criminal Act significantly increases penalties for repeat offenders with violent criminal histories. To qualify for the enhancement, prosecutors must prove that the defendant has at least three prior convictions for violent felonies or serious drug offenses that were committed on separate occasions. When these conditions are met, the mandatory minimum sentence jumps from a maximum of 10 years to a minimum of 15 years.
The Sixth Circuit's opinion appears to address constitutional challenges that may have been raised regarding the traffic stop and subsequent search. While the full text of the opinion was not available, the court's affirmance suggests that it found no Fourth Amendment violations in how the evidence was obtained.
Traffic stops that lead to firearm discoveries often raise questions about the scope of police authority during routine encounters. Officers generally may observe items in plain view during lawful traffic stops, but searches typically require either consent, probable cause, or a warrant. In this case, police obtained a search warrant after initially spotting the gun and learning of Conner's criminal history.
The case reflects ongoing federal efforts to enforce gun laws, particularly against individuals with violent criminal backgrounds. Federal prosecutors often pursue felon-in-possession cases because they carry significant penalties and help remove firearms from individuals legally prohibited from having them.
Conner's 200-month sentence, equivalent to approximately 16.7 years, demonstrates the severe consequences that can result from firearm possession by prohibited persons, especially those with extensive criminal histories. The sentence exceeds the 15-year mandatory minimum, suggesting the court may have considered additional factors in determining the appropriate punishment.
The Sixth Circuit Court of Appeals covers federal appeals from district courts in Kentucky, Michigan, Ohio, and Tennessee. The court regularly handles appeals involving federal firearms prosecutions, which have become increasingly common as federal authorities prioritize gun crime enforcement.
The opinion was marked "not recommended for publication," indicating that while it resolves the specific case, it does not establish new legal precedent. Such designations are common for routine appeals that apply established law to particular facts without breaking new legal ground.
Conner's case joins thousands of similar prosecutions brought annually under federal firearms statutes. The Department of Justice has made enforcement of gun laws a priority, particularly targeting individuals with violent criminal histories who illegally possess weapons.