The Eighth Circuit Court of Appeals affirmed an enhanced sentence for a Minnesota man convicted of being a felon in possession of a firearm, rejecting multiple constitutional and procedural challenges in *United States v. Shaninth Michael Ray* (8th Cir. 2026).
Shaninth Michael Ray had pleaded guilty to violating federal law as a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). Despite his guilty plea, the U.S. District Court for the District of Minnesota imposed a sentence above the federal sentencing guidelines range, prompting Ray's appeal to the Eighth Circuit.
The case presented multiple legal challenges that Ray raised both through counsel and in pro se filings. Ray's primary arguments included a constitutional challenge to the federal statute based on the Commerce Clause, a motion to suppress evidence, procedural challenges to his indictment, and claims of ineffective assistance of counsel. Ray also moved for appointment of new counsel during the proceedings.
In the unpublished per curiam opinion filed Feb. 6, 2026, the three-judge panel consisting of Circuit Judges Loken, Kelly, and Grasz rejected Ray's constitutional challenge to the federal gun possession statute. The court held that Ray's facial and as-applied challenges to 18 U.S.C. § 922(g)(1) were foreclosed by binding Eighth Circuit precedent, specifically citing *United States v. Wilson*, 939 F.3d 929, 931 (8th Cir. 2019).
The appeals court applied de novo review to the district court's legal determinations, as established in the *Wilson* precedent. This standard of review means the appellate court examined the legal questions independently without deference to the lower court's conclusions.
Ray's counsel argued that the enhanced sentence imposed by Chief Judge Patrick J. Schiltz of the U.S. District Court for the District of Minnesota was substantively unreasonable. However, the Eighth Circuit found no error in the district court's sentencing decision, effectively upholding the above-Guidelines sentence.
The federal statute at issue, 18 U.S.C. § 922(g)(1), prohibits any person who has been convicted of a felony from possessing firearms or ammunition that have been shipped or transported in interstate commerce. This law has been a cornerstone of federal firearms enforcement, particularly targeting repeat offenders with prior felony convictions.
Ray's Commerce Clause challenge represented an attempt to argue that the federal government lacked constitutional authority to prosecute him under the interstate commerce power. Such challenges have become more common following recent Supreme Court decisions that have narrowed federal authority in some areas, but federal courts have generally continued to uphold gun possession statutes against Commerce Clause attacks.
The court also addressed Ray's motion to dismiss the indictment and his request to suppress evidence. Ray had argued that certain evidence should be suppressed and that the indictment should be dismissed based on that allegedly tainted evidence. The appeals court found these arguments unsuccessful, maintaining that the district court properly denied the motion to dismiss.
Ray's ineffective assistance of counsel claim and his motion for appointment of new counsel were also addressed in the proceedings. These claims suggest Ray believed his legal representation was inadequate, though the court's decision indicates these arguments were not successful in overturning his conviction or sentence.
The case illustrates the continued robust enforcement of federal firearms laws against convicted felons. Federal prosecutors frequently pursue charges under § 922(g)(1) as part of efforts to reduce gun violence, particularly in cases involving repeat offenders with prior felony convictions.
Sentencing above the federal guidelines range, as occurred in Ray's case, typically requires judges to provide specific justifications based on factors such as the defendant's criminal history, the nature of the offense, and public safety considerations. The fact that the Eighth Circuit upheld the enhanced sentence suggests the district court properly articulated its reasoning for the departure from the guidelines.
The unpublished nature of the decision means it will not serve as binding precedent for future cases, though it can be cited for its persuasive value. Unpublished opinions are common in straightforward appeals where established legal principles are applied to specific fact patterns without creating new legal standards.
Ray's case was submitted to the Eighth Circuit on Jan. 28, 2026, and decided just over a week later, indicating the court found the legal issues relatively straightforward despite the multiple challenges raised. The quick turnaround time suggests the panel viewed the precedential authority as clearly controlling Ray's various constitutional and procedural arguments.
The decision reinforces the Eighth Circuit's consistent application of federal firearms laws and demonstrates the difficulty defendants face in mounting successful constitutional challenges to well-established statutes like § 922(g)(1).