The U.S. Court of Appeals for the Eighth Circuit affirmed the constitutionality of federal law prohibiting felons from possessing firearms, rejecting a defendant's Second Amendment challenge in *United States v. Crawford*.
Juwan Dupri Crawford was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1), a federal statute that makes it unlawful for anyone who has been convicted of a felony to possess firearms or ammunition. Crawford moved to dismiss the indictment, arguing that the law violated the Second Amendment both facially and as applied to his specific case.
The U.S. District Court for the Southern District of Iowa denied Crawford's motion to dismiss. Crawford then entered a guilty plea to the charge while reserving his right to appeal the denial of his constitutional challenge, allowing him to contest the law's validity while accepting responsibility for the underlying conduct.
On appeal, Crawford reasserted his contention that § 922(g)(1) violates the Second Amendment. However, the Eighth Circuit panel, consisting of Circuit Judges Loken, Arnold, and Gruender, issued a brief per curiam opinion rejecting his arguments based on established circuit precedent.
The court noted that Crawford's arguments had already been considered and rejected in recent Eighth Circuit decisions. The panel specifically cited *United States v. Jackson*, a 2024 decision where the Eighth Circuit addressed similar Second Amendment challenges to the felon-in-possession statute. In *Jackson*, the court held that § 922(g)(1) does not violate the Second Amendment, analyzing the law under the framework established by the Supreme Court's decisions in *District of Columbia v. Heller* and *New York State Rifle & Pistol Association v. Bruen*.
The court also referenced *United States v. Mitchell*, a December 2025 unpublished per curiam decision that similarly rejected Second Amendment challenges to the felon-in-possession law. These precedential decisions established the Eighth Circuit's position that the federal prohibition on firearm possession by convicted felons remains constitutionally permissible.
Crawford urged the appeals court to reconsider its holding in *Jackson*, but the three-judge panel explained that it lacked authority to overrule existing circuit precedent. Under federal appellate court rules, only the full Eighth Circuit sitting en banc can reconsider and potentially overturn established circuit precedent. The court cited *United States v. Escobar* to support this procedural limitation on panel authority.
The felon-in-possession statute has faced renewed scrutiny following the Supreme Court's 2022 decision in *Bruen*, which established a new framework for analyzing Second Amendment cases. Under *Bruen*, courts must determine whether modern firearm regulations are consistent with the nation's historical tradition of firearm regulation, rather than applying the intermediate scrutiny test that many circuits previously used.
Despite this changed constitutional landscape, federal appeals courts have generally continued to uphold § 922(g)(1) against Second Amendment challenges. Courts have found that historical evidence supports prohibiting dangerous individuals, including convicted felons, from possessing firearms as consistent with the original understanding of the Second Amendment.
The Eighth Circuit's decision in *Crawford* represents the latest in a series of post-*Bruen* rulings affirming the constitutionality of felon-in-possession laws. Similar challenges have been rejected by other federal circuits, creating a body of appellate precedent supporting the continued enforcement of § 922(g)(1).
Crawford's case was submitted to the court on Jan. 12, 2026, and decided on Feb. 2, 2026. The opinion was designated as unpublished, meaning it carries less precedential weight than published decisions but still represents the circuit's current position on these constitutional questions.
The decision affects individuals with felony convictions who seek to challenge their exclusion from Second Amendment protections. While Crawford argued that the blanket prohibition violated his constitutional rights, the Eighth Circuit maintained that convicted felons fall outside the scope of Second Amendment protection based on historical understanding and contemporary judicial interpretation.
For criminal defense attorneys handling felon-in-possession cases, the decision reinforces the limited prospects for successful Second Amendment challenges to § 922(g)(1) in the Eighth Circuit. The court's reliance on recent precedent suggests that such challenges will continue to face an uphill battle absent intervention by the full circuit or the Supreme Court.
The case also illustrates the procedural strategy of pleading guilty while reserving appeal rights on constitutional questions, allowing defendants to challenge the underlying law while accepting factual responsibility for their conduct. This approach enables appellate review of purely legal questions without requiring a full trial on the underlying charges.