United States v. Deago Eddings, 24-1166

Deago Eddings was found in possession of a firearm during a traffic stop while on state parole following convictions for serious felonies.
He was charged under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm.
Eddings moved to suppress evidence, but the motion was denied, and he pleaded guilty.
After new precedent (Range v. Attorney General), Eddings sought to withdraw his plea and dismiss the indictment, challenging § 922(g)(1) on Second Amendment and Commerce Clause grounds.
The District Court denied his motions and sentenced him to 27 months in prison.
Eddings appealed the denial of his motions and the constitutionality of his conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of § 922(g)(1) as applied	Law is unconstitutional under Second Amendment after Range	Law is valid for those on parole	Statute is constitutional as applied
Facial constitutionality of § 922(g)(1)	Law is unconstitutional in all circumstances	Law valid under Moore/Quailes	Facial challenge fails
Commerce Clause challenge to § 922(g)(1)	Statute exceeds congressional authority	Law is settled as constitutional	Commerce challenge foreclosed by precedent

Range v. Attorney General, 69 F.4th 96 (3d Cir. 2023) (en banc) (invalidated § 922(g)(1) as applied to certain misdemeanants not covered by historical tradition)
United States v. Moore, 111 F.4th 266 (3d Cir. 2024) (approved § 922(g)(1) disarmament of convicts on supervised release consistent with history/tradition)
United States v. Rahimi, 602 U.S. 680 (2024) (reaffirmed historical analysis for firearm restrictions)
United States v. Singletary, 268 F.3d 196 (3d Cir. 2001) (rejected Commerce Clause challenges to § 922(g)(1))
United States v. Quailes, 126 F.4th 215 (3d Cir. 2025) (extended Moore’s holding to state parole and probation)