United States v. Raphael Jermaine Williams, Jr.
24-1409
6th Cir.Apr 17, 2025Background
- Raphael Williams was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1).
- Williams had recent felony convictions in Michigan for crimes including receiving and concealing a stolen vehicle, fleeing police, malicious destruction of police property, and assaulting/resisting/obstructing a police officer, as well as a juvenile robbery adjudication.
- While on probation—which forbade firearm possession—Williams posted social media content showing him with firearms and making threats, and police found a loaded firearm with a suspected machine-gun conversion device in his home.
- The district court dismissed the indictment, finding § 922(g)(1) unconstitutional as applied to Williams under New York State Rifle & Pistol Ass’n v. Bruen.
- The government appealed, and the Sixth Circuit considered the case under new precedent from United States v. Erick Williams and United States v. Goins.
Issues
| Issue | Williams's Argument | Government's Argument | Held |
|---|---|---|---|
| Constitutionality of § 922(g)(1) | Statute unconstitutional as applied after Bruen | Statute valid as applied to dangerous individuals | § 922(g)(1) is constitutional as applied to Williams |
| Dangerousness Standard | Williams is not dangerous despite record, cites youth | Violent felonies and social media posts show dangerousness | Williams' record demonstrates dangerousness |
| Probation Violation | Probation violation insufficient to prove dangerousness | Probation violation plus felonies show danger | Violation supports dangerousness finding |
| Application of Circuit Precedent | Erick Williams/Goins wrongly decided | Those cases are binding; apply to this case | Circuit precedent controls; dismissal reversed |
Key Cases Cited
- United States v. Erick Williams, 113 F.4th 637 (6th Cir. 2024) (upheld § 922(g)(1) as constitutional as applied to dangerous persons)
- United States v. Goins, 118 F.4th 794 (6th Cir. 2024) (statute constitutional as applied to probationers who violate firearm conditions)
- New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022) (Second Amendment challenge framework for firearm regulations)
- United States v. Rahimi, 602 U.S. 680 (2024) (discusses tradition-based analysis for firearm regulation constitutionality)