The Eighth Circuit Court of Appeals issued a mixed ruling in *United States v. Ledvina*, vacating a defendant's conviction for unlawful firearm possession by a drug user while affirming other aspects of the case. The court remanded the matter for further proceedings to address Alexander Wesley Ledvina's Second Amendment as-applied challenge.
Ledvina had appealed the U.S. District Court for the Northern District of Iowa's decision denying his motion to dismiss federal firearms charges. The grand jury indicted Ledvina on two counts: unlawful possession of a firearm by a drug user under 18 U.S.C. § 922(g)(3) and § 924(a)(8), and making a false statement during a firearm purchase under 18 U.S.C. § 924(a)(1)(A).
The appeals court's decision relied heavily on recent Eighth Circuit precedents that have reshaped the analysis of federal gun laws in light of Second Amendment challenges. Circuit Judge Erickson, writing for the panel that included Chief Judge Colloton and Circuit Judge Stras, cited the court's decisions in *United States v. Perez*, 145 F.4th 800 (8th Cir. 2025), and *United States v. Cooper*, 127 F.4th 1092 (8th Cir. 2025), as controlling precedent that necessitated vacating Ledvina's conviction under § 922(g)(3).
The court's reliance on *Perez* and *Cooper* suggests these recent decisions have established new analytical frameworks for evaluating Second Amendment challenges to federal firearms prohibitions, particularly those targeting drug users. While the specific holdings in those cases were not detailed in the available portions of the *Ledvina* opinion, their influence was significant enough to compel the appeals court to vacate the conviction and order a new examination of the constitutional issues.
The case represents the latest development in ongoing litigation challenging federal firearms laws on Second Amendment grounds. Since the Supreme Court's decision in *New York State Rifle & Pistol Association v. Bruen* in 2022, which established a new test requiring gun regulations to be consistent with the nation's historical tradition of firearm regulation, numerous federal firearms prohibitions have faced renewed constitutional scrutiny.
The specific charge under 18 U.S.C. § 922(g)(3) prohibits any person who is an unlawful user of or addicted to any controlled substance from possessing firearms. This provision has been increasingly challenged in federal courts as defendants argue it violates their Second Amendment rights, particularly in cases involving marijuana use in states where it has been legalized or decriminalized.
Ledvina's case originated in the Northern District of Iowa's Cedar Rapids division, where the district court had denied his motion to dismiss the charges. The case was submitted to the Eighth Circuit on Sept. 19, 2025, and the appeals court issued its opinion on Feb. 6, 2026.
While the court vacated the drug user possession conviction, it affirmed the district court's decision on all other issues, including presumably the denial of Ledvina's motion to dismiss the false statement charge. This suggests the court found the Second Amendment challenge specifically applicable to the drug user prohibition rather than to federal firearms laws more broadly.
The remand for further proceedings indicates the district court will need to conduct additional analysis of Ledvina's as-applied challenge to determine whether the federal prohibition on drug users possessing firearms violates his individual Second Amendment rights. An as-applied challenge argues that while a law might be constitutional in general, its application to the specific circumstances of the defendant violates constitutional rights.
The decision reflects the ongoing evolution of Second Amendment jurisprudence in the federal circuit courts. The Eighth Circuit, which covers Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota, has been actively addressing these constitutional challenges as they arise in federal firearms prosecutions.
The false statement charge under § 924(a)(1)(A) typically involves allegations that a defendant lied on federal forms required for firearm purchases, such as Form 4473, which requires purchasers to answer questions about their eligibility to possess firearms, including questions about drug use.
The case will now return to the district court for further proceedings consistent with the appeals court's ruling. The district court will need to apply the constitutional analysis framework established in *Perez* and *Cooper* to determine whether Ledvina's specific circumstances warrant dismissal of the drug user possession charge on Second Amendment grounds.
This development adds to a growing body of circuit court decisions grappling with the intersection of federal drug laws and Second Amendment rights, an area of law that continues to evolve as courts interpret recent Supreme Court precedents in the context of longstanding federal firearms regulations.