USA v. Landrum
Split Score
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Case Summary
Disposition
Affirmed
The Fifth Circuit rejected Lester Landrum’s challenge to his conviction for possession of a firearm by a felon under 18 U.S.C. § 922(g)(1). The court held that the statute is not unconstitutionally vague and that all of Landrum’s other constitutional arguments are foreclosed by binding Fifth Circuit precedent, thereby affirming the conviction.
Circuit Split Identified
Legal Issue
Whether 18 U.S.C. § 922(g)(1) is categorically constitutional for all felons under the Second Amendment after N.Y. State Rifle & Pistol Ass’n v. Bruen, or whether courts must conduct an as-applied, predicate-offense-specific historical-tradition analysis.
Circuit Positions
§ 922(g)(1) is categorically constitutional for all felons; broad historical tradition suffices.
§ 922(g)(1) is constitutional only as applied to felons whose specific predicate offenses have a well-established historical analogue supporting disarmament.
Conflict Summary
The Fifth Circuit applies an offense-specific, as-applied approach, requiring the government to show a historical analogue for disarming persons with the particular predicate felony. The Fourth and Eighth Circuits hold that § 922(g)(1) is categorically constitutional for all felons based on a broad historical tradition of felon disarmament, without individualized analysis.