Ryan Anthony Johnson lost his appeal against his conviction for possessing a firearm as a convicted felon. The Eleventh Circuit Court of Appeals affirmed the lower court’s decision, siding with the government’s argument that the law prohibiting felons from owning guns is constitutional.
The Core Issue: Second Amendment Rights and Felons
Johnson argued that 18 U.S.C. § 922(g)(1), the federal law that prevents convicted felons from possessing firearms, is unconstitutional. He claimed it violated his Second Amendment rights, which guarantee the right to keep and bear arms.
The Government’s Argument and the Court’s Response
The government moved for a summary affirmance, essentially arguing that Johnson’s case was so clear-cut that the court didn’t need to spend much time on it. The court agreed. They found that the government’s position was “clearly correct as a matter of law.”
The Legal Framework: Precedent and the Second Amendment
The court’s decision hinged on established legal precedent, meaning previous rulings that courts must follow. The court emphasized that it is bound by its prior decisions unless those decisions have been overturned by the full court or the Supreme Court.
The court referenced the Supreme Court’s landmark Second Amendment case, *District of Columbia v. Heller* (2008), which established that the Second Amendment protects an individual’s right to possess handguns in the home for self-defense. However, *Heller* also stated that this right is not unlimited and specifically noted that “nothing in [its] opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons.” The Supreme Court labeled these prohibitions as “presumptively lawful.”
Key Precedents in the Eleventh Circuit
The Eleventh Circuit Court of Appeals had previously addressed the constitutionality of § 922(g)(1) in *United States v. Rozier* (2010). In *Rozier*, the court held that the law was constitutional, even if a felon possessed a firearm purely for self-defense.
The Supreme Court’s 2022 decision in *New York State Rifle & Pistol Association, Inc. v. Bruen* changed the way courts analyze Second Amendment challenges. *Bruen* established a two-part test: first, courts must determine if the individual’s conduct is covered by the Second Amendment’s plain text, and then consider whether the regulation is consistent with the nation’s historical tradition of firearm regulation.
However, the Eleventh Circuit had to consider how *Bruen* impacted its prior ruling in *Rozier*. In *United States v. Dubois* (2024), the Eleventh Circuit held that *Bruen* did not overrule *Rozier*. The court reasoned that *Bruen* did not directly address or invalidate the felon-in-possession prohibition. Later, after the Supreme Court’s ruling in *United States v. Rahimi* (2024), which addressed a different gun law, the Eleventh Circuit reaffirmed its position in *Dubois II* (2025), stating that neither *Bruen* nor *Rahimi* undermined *Rozier*.
The Court’s Reasoning in Johnson’s Case
The court in Johnson’s case explicitly stated that the government was correct in its argument that Johnson’s challenge was “foreclosed” by the *Dubois II* decision. Because *Dubois II* held that *Rozier* remained good law, the court was bound by *Rozier*. Therefore, the court concluded that § 922(g)(1) was constitutional, and affirmed the lower court’s decision.
In Simple Terms
Essentially, the court said that because it had already ruled on this issue in the past (*Rozier*), and because that ruling hadn’t been overturned by the Supreme Court or the full Eleventh Circuit, it had to follow its previous decision. The court viewed the government’s argument as correct because the legal precedent clearly supported the constitutionality of the law.