United States v. Daniel Medina
670 F. App'x 219
| 5th Cir. | 2016Background
- Defendant Daniel Ray Medina pleaded guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g).
- The factual resume admitted that the firearm was not manufactured in Texas and had “necessarily traveled at an indeterminate time to Texas.”
- Medina did not object at the plea hearing to the sufficiency of the factual basis, so review is for plain error.
- Medina argued, relying on Bond v. United States, that § 922(g) should not reach possession when the firearm’s interstate travel occurred at an unknown, remote time, because that would allow regulation of activity with only a minimal commerce nexus.
- The district court found the plea had a sufficient factual basis; the Fifth Circuit considered whether that ruling was a clear or obvious error and whether it affected Medina’s substantial rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of factual basis for plea under § 922(g) | Medina: plea insufficient because only shows past, indeterminate interstate travel; minimal commerce nexus | Government/District Court: admitted facts (firearm not made in Texas and traveled to Texas) satisfy § 922(g) as interpreted by circuit precedent | Affirmed — no plain or obvious error; factual basis sufficient under circuit law |
| Effect of Bond v. United States on § 922(g) application | Medina: Bond suggests limits on federal reach where commerce nexus is minimal | Government: Bond did not abrogate circuit precedent interpreting § 922(g) broadly | Bond did not abrogate Fifth Circuit precedents; Bond not controlling here |
| Standard of review for Rule 11(b)(3) challenge | Medina: preserves argument but accepts plain-error review | Government: objection forfeited; plain-error standard applies | Plain-error standard governs; Medina failed to show clear/obvious error or prejudice |
| Whether past connection to interstate commerce suffices for § 922(g) | Medina: past, remote connection insufficient if indeterminate | Government: past connection is sufficient per Fifth Circuit precedent | Past connection suffices; Fifth Circuit precedent controls |
Key Cases Cited
- United States v. Trejo, 610 F.3d 308 (5th Cir. 2010) (Rule 11(b)(3) requires factual basis for a guilty plea)
- Puckett v. United States, 556 U.S. 129 (2009) (plain-error review framework)
- United States v. Shelton, 937 F.2d 140 (5th Cir. 1991) (Congress intended a broad commerce connection in § 922(g))
- United States v. Fitzhugh, 984 F.2d 143 (5th Cir. 1993) (possession of a firearm with a past interstate connection violates § 922(g))
- Bond v. United States, 134 S. Ct. 2077 (2014) (interpreting limits of federal power under certain statutory applications)