United States v. Daniels, 610 F.Supp.3d 892

Defendant Patrick Darnell Daniels, Jr. is indicted under 18 U.S.C. § 922(g)(3) for possessing a firearm while an unlawful user of a controlled substance.
Daniels moved to dismiss the indictment, arguing § 922(g)(3) is unconstitutional under the Second Amendment in light of the Supreme Court’s decision in New York State Rifle & Pistol Ass’n v. Bruen.
The Court applied Bruen’s mandated two-step focus on (1) whether the Second Amendment’s text covers the conduct and (2) whether the regulation is consistent with this Nation’s historical tradition of firearm regulation.
The Court acknowledged textual questions about whether unlawful drug users are among the “people” protected by the Second Amendment but proceeded to the historical‑tradition analysis.
Relying on circuit precedent (notably United States v. Yancey and United States v. Patterson) and other historical analogues disarming “risky” or “unvirtuous” persons, the Court found § 922(g)(3) consistent with historical tradition.
The Court denied Daniels’s motion to dismiss, concluding § 922(g)(3) survives scrutiny under Heller and Bruen.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 922(g)(3) regulates conduct covered by the Second Amendment text	U.S.: Unlawful users can be excluded from the class of “the people”; statute targets non‑law‑abiding persons	Daniels: Possession of a firearm is plainly covered by the Amendment and thus merits protection under Bruen’s textual inquiry	Court: § 922(g)(3) regulates firearm possession (textually covered), but acknowledged some doubt about whether unlawful users are among the protected “people”; proceeded to historical analysis
Whether § 922(g)(3) is consistent with the Nation’s historical tradition of firearm regulation (Bruen test)	U.S.: Congress and many states historically disarmed dangerous or unvirtuous persons (felons, alcoholics, habitual drug users), so § 922(g)(3) fits longstanding tradition	Daniels: No sufficiently close founding‑era analogue; Bruen requires historical support for modern restrictions	Court: Found adequate historical analogues and circuit authority (e.g., Yancey, Patterson) analogizing drug‑user disarmament to longstanding exclusions and upheld § 922(g)(3)
Whether the indictment must be dismissed	U.S.: Opposes dismissal; statute constitutional	Daniels: Requests dismissal based on alleged Second Amendment violation	Court: Denied the motion to dismiss

District of Columbia v. Heller, 554 U.S. 570 (2008) (recognizes individual right to possess arms for self‑defense but affirms longstanding prohibitions on felons and the mentally ill)
New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 597 U.S. _ (2022) (prescribes text‑and‑history framework for Second Amendment challenges; permits historical‑analogy reasoning)
McDonald v. City of Chicago, 561 U.S. 742 (2010) (incorporates Second Amendment against the states and reiterates Heller’s assurances about longstanding prohibitions)
United States v. Yancey, 621 F.3d 681 (7th Cir. 2010) (historical analysis supporting constitutionality of § 922(g)(3) as disarming dangerous persons)
United States v. Patterson, 431 F.3d 832 (5th Cir. 2005) (characterizes § 922(g)(3) as a narrowly tailored exception for high‑risk classes)
Nat’l Rifle Ass’n of Am. v. Bureau of Alcohol, Tobacco, Firearms & Explosives, 700 F.3d 185 (5th Cir. 2012) (discusses historical foundations for modern firearm restrictions)