United States v. Davis, 406 F. App'x 52

Tip from confidential informant linked Davis’s son to drug trafficking and weapons; police obtained a search warrant for Davis’s home.
During the search Davis directed officers to a handgun and ammunition in his closet.
Davis knew his felony conviction for conspiring to distribute heroin prohibited firearm possession and claimed he kept the gun for protection after a home invasion.
Davis pled guilty to possession of a firearm as a felon under 18 U.S.C. § 922(g)(1).
District court sentenced Davis to 24 months, three months below the bottom of the guidelines range (27–33).
On appeal, counsel moved to withdraw under Anders; the court limited review to two issues and affirmed

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutional challenge to § 922(g)(1)?	Davis argued § 922(g)(1) infringes the Second Amendment.	Government argues Heller and McDonald uphold felon disqualification.	Frivolous to challenge; denial of indictment affirmed.
Reasonableness of below-range sentence?	Davis contends the sentence is unreasonable and should be above the range.	District court properly calculated guidelines; usual presumption of reasonableness applies to below-range sentence.	Sentence reasonable; no basis to disturb.

Heller v. District of Columbia, 554 U.S. 570 (U.S. 2008) (felon disqualification dictum upheld; core Second Amendment analysis not undermined)
McDonald v. City of Chicago, 130 S. Ct. 3020 (U.S. 2010) (reiterates Heller assurances on felon disqualification)
Rita v. United States, 551 U.S. 338 (U.S. 2007) (presumption of reasonableness for within-guidelines sentences)
United States v. Williams, 616 F.3d 685 (7th Cir. 2010) (discusses reasonableness review in this circuit)
United States v. Skoien, 614 F.3d 638 (7th Cir. 2010) (en banc; related to firearms and appellate review)
United States v. Pape, 601 F.3d 743 (7th Cir. 2010) (reasonableness and guidelines application)