Anthony Browne v. Kimberly Reynolds
Split Score
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Case Summary
Disposition
Affirmed
The Eighth Circuit affirmed the district court’s dismissal of Anthony A. Browne’s suit challenging Iowa’s lifetime bar on firearm possession and restoration for forcible felons. The panel held that, under its own precedent in United States v. Jackson and consistent with the historical-tradition framework of Bruen, a categorical prohibition on felons possessing firearms—without an individualized dangerousness inquiry—does not violate the Second Amendment.
Circuit Split Identified
Legal Issue
Whether the Second Amendment allows a categorical ban on firearm possession by felons (or requires an individualized dangerousness determination).
Circuit Positions
Categorical felon dispossession statutes are constitutional; no individualized dangerousness finding required.
Categorical felon dispossession statutes can violate the Second Amendment; individualized assessment or narrower tailoring required.
Conflict Summary
The Eighth, Fourth, Ninth, Tenth, and Eleventh Circuits uphold categorical felon-in-possession bans as facially constitutional under Bruen, requiring no case-by-case assessment. In contrast, the Third Circuit in Range v. Attorney General held that, at least for certain non-violent felons, the government must justify the restriction with individualized evidence or historical analogues, deeming a categorical bar unconstitutional.