United States v. Rahimi, 117 F.4th 331

Zackey Rahimi was convicted under 18 U.S.C. § 922(g)(8) for possessing a firearm while subject to a domestic violence restraining order.
Rahimi brought a facial challenge to the constitutionality of § 922(g)(8), relying heavily on the Supreme Court's decision in N.Y. State Rifle & Pistol Association v. Bruen.
The Fifth Circuit initially upheld the conviction and rejected Rahimi's constitutional challenge, but withdrew its opinion following Bruen.
On remand, the Fifth Circuit panel found § 922(g)(8) unconstitutional under Bruen and vacated the conviction.
The Supreme Court reversed that decision, holding that § 922(g)(8) is facially constitutional and clarifying the historical analysis under Bruen.
Rahimi also challenged the district court's decision to run his federal sentence consecutively to anticipated state sentences, but this was affirmed.

Issue	Rahimi's Argument	USA's Argument	Held
Constitutionality of § 922(g)(8)	Statute unconstitutionally burdens 2nd Amendment rights	Statute constitutionally disarms dangerous persons	§ 922(g)(8) is facially constitutional
Sentencing: Consecutive vs. Concurrent Sentences	State conduct was relevant so sentences should be concurrent	Federal and state offenses not "relevant conduct"	Consecutive sentencing affirmed

N.Y. State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022) (established framework for evaluating Second Amendment challenges based on text and history)
United States v. Lopez, 514 U.S. 549 (1995) (struck down Gun-Free School Zones Act as exceeding Commerce Clause authority)
Setser v. United States, 566 U.S. 231 (2012) (district courts have discretion to order federal sentences to run consecutive to anticipated state terms)
McDonald v. City of Chicago, 561 U.S. 742 (2010) (Second Amendment rights applied to states, not second-class constitutional rights)