United States v. Jaylin Morton
123 F.4th 492
6th Cir.2024Background
- Jaylin Morton was indicted for violating 18 U.S.C. § 922(g)(1) by possessing a firearm as a felon.
- Morton had a significant criminal history, including multiple felonies such as possessing a firearm as a felon, fleeing police, burglary, intimidation, assault, and domestic violence incidents.
- He moved to dismiss the indictment, claiming § 922(g)(1) was unconstitutional as applied to him based on the Second Amendment and recent Supreme Court precedent (Bruen).
- The district court denied his motion, citing his criminal history as evidence of dangerousness.
- Morton conditionally pled guilty, retaining the right to appeal the denial of his motion to dismiss.
- On appeal, Morton argued that his criminal history did not justify permanent disarmament and that the historical tradition does not support Congress's authority to disarm felons.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of § 922(g)(1) as applied | His prior convictions were for nonviolent crimes, not justifying permanent disarmament under the Second Amendment | Morton's criminal history, including violent and firearm-related felonies, demonstrates he is dangerous so restriction is justified | § 922(g)(1) is constitutional as applied to Morton due to his demonstrated dangerousness |
| Scope of Second Amendment protections | Congress cannot disarm felons since such power did not exist federally at the founding, only with states | Both federal and state historical laws can inform the Second Amendment's reach | Court rejects limitation to only federal laws, supporting consideration of wider historical tradition |
| Sufficiency of district court's dangerousness finding | District court applied an insufficient inquiry under precedents | District court properly relied on the nature of convictions and available records | District court’s individualized assessment was adequate |
| Potential for as-applied challenge by non-dangerous felons | Morton may not be dangerous, so § 922(g)(1) is unconstitutional as applied | Court can and should consider entire criminal history to assess dangerousness | Full criminal history shows Morton is dangerous; as-applied challenge rejected |
Key Cases Cited
- New York State Rifle & Pistol Ass'n v. Bruen, 597 U.S. 1 (Sup. Ct. 2022) (sets test for historical tradition in evaluating Second Amendment cases)
- District of Columbia v. Heller, 554 U.S. 570 (Sup. Ct. 2008) (recognized individual Second Amendment right, subject to historical limits)
- United States v. Rahimi, 602 U.S. 680 (Sup. Ct. 2024) (upholds disarmament of those posing danger, using historical analogues)
- United States v. Williams, 113 F.4th 637 (6th Cir. 2024) (sixth circuit precedent finding § 922(g)(1) constitutional as applied to felons with violent criminal history)