United States v. LANIER, 2:22-cr-00469

Lanier, a convicted felon with prior violent and firearm-related convictions (including aggravated assault and illegal firearm possession), was on parole in 2022.
Recorded calls and POAG investigation located Lanier at his girlfriend’s apartment, where a June 16, 2022 search recovered eight firearms, drugs, and drug-sale paraphernalia; Lanier admitted possession of the firearms.
Indictment (Dec. 20, 2022) charges Lanier with one count of possession of a firearm by a felon under 18 U.S.C. § 922(g)(1).
Lanier moved to dismiss, arguing § 922(g)(1) is unconstitutional as applied after Bruen and Range, and facially invalid, vague, and inconsistent with the original public meaning of the Commerce Clause.
The Government opposed: § 922(g)(1) applies because Lanier wasn’t a law-abiding citizen, he was on parole, and historical tradition supports disarming dangerous persons; it also argued the facial and vagueness challenges fail and Commerce Clause arguments are foreclosed by precedent.
The Court denied Lanier’s motion, holding § 922(g)(1) constitutional as applied and facially, and not unconstitutionally vague or barred by Commerce Clause precedent.

Issue	Government's Argument	Lanier's Argument	Held
As-applied Second Amendment challenge under Bruen/Range	Lanier is not a law-abiding person; historical tradition supports disarming dangerous individuals and felons	§ 922(g)(1) cannot constitutionally apply to him post-Bruen/Range	Denied — government met its historical-tradition burden; Lanier unlike Range; § 922(g)(1) applies
Facial invalidation of § 922(g)(1)	Statute is permissible in many applications; Salerno standard not met	Statute is unconstitutional in all applications	Denied — Lanier failed to show statute invalid in all applications
Vagueness challenge	Statute gives clear notice: bars those convicted of crimes punishable by >1 year	Statute is impermissibly vague	Denied — provides fair notice and clear standards
Commerce Clause / original public meaning challenge	Precedent forecloses reexamination of Congress’s commerce power	§ 922(g)(1) inconsistent with original public meaning of Commerce Clause	Denied — binding precedent (e.g., Singletary) forecloses this argument

District of Columbia v. Heller, 554 U.S. 570 (2008) (Second Amendment not absolute; long-standing prohibitions on felons permissible)
New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 142 S. Ct. 2111 (2022) (adopted historical-tradition test for firearm regulations)
Range v. Attorney General, 69 F.4th 96 (3d Cir. 2023) (as-applied § 922(g)(1) invalid for a nonviolent offender lacking historical analogue)
United States v. Salerno, 481 U.S. 739 (1987) (facial-challenge standard: statute invalid only if no lawful applications exist)
United States v. Williams, 553 U.S. 285 (2008) (vagueness standard: fair notice and protection against arbitrary enforcement)
United States v. Mitchell, 652 F.3d 387 (3d Cir. 2011) (explaining facial-challenge burdens and Salerno rule)
NRA v. Bureau of Alcohol, Tobacco, Firearms & Explosives, 700 F.3d 185 (5th Cir. 2012) (historical evidence that dangerous persons were disarmed)
United States v. Singletary, 268 F.3d 196 (3d Cir. 2001) (Commerce Clause precedent cited to reject as-applied Commerce-Clause attacks)