United States v. Sarraj, 665 F.3d 916

Sarraj, a felon, sought to buy guns in Illinois for protection after a dispute with criminal associates.
Agents used a reverse-sting by presenting as gun sellers through an ATF confidential informant.
Guns offered were prop, manufactured outside Illinois, to satisfy interstate commerce element.
Sarraj bought two handguns and was later charged with felon in possession under § 922(g)(1).
District court denied Sarraj’s motions to modify the jury instruction and to dismiss, and he entered a conditional guilty plea.
Sarraj appealed arguing federalism/Lopez-based limits on § 922(g)(1) as applied to reverse-stings; the government argued the reverse-sting approach is constitutional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reverse-sting operations violate federalism limits on § 922(g)(1).	Sarraj argues opposite federalism constraints limit interstate nexus via the guns’ origin.	United States argues statute remains constitutional with minimal interstate nexus; reverse stings are permissible.	Constitutional; reverse stings constitutional under § 922(g)(1).
Whether the interstate-commerce element is satisfied when guns are introduced as prop guns.	Sarraj contends removal to ATF prop collection defeats interstate nexus.	United States contends minimal nexus suffices, even if guns later become prop items.	Sufficient minimal interstate nexus established; nexus not erased by government action.
Whether Sarraj preserved the right to appeal the district court rulings despite the conditional plea.	Sarraj preserved the appeal via conditional plea and pretrial motions.	United States contends waiver or scope limits apply.	No waiver; Sarraj preserved appeal rights consistent with Rule 11(a)(2).

United States v. Rice, 520 F.3d 811 (7th Cir. 2008) (interstate move satisfies 922(g)(1) nexus when gun moved across state lines)
Scarborough v. United States, 431 U.S. 563 (U.S. 1977) (requires minimal nexus to support federal authority over possession)
United States v. Lopez, 514 U.S. 549 (U.S. 1995) (Lopez distinguished from minimal-nexus firearms provisions)
United States v. Lemons, 302 F.3d 769 (7th Cir. 2002) (Lopez did not invalidate § 922(g)(1); minimal nexus approach allowed)
United States v. Lewis, 100 F.3d 49 (7th Cir. 1996) (Lopez does not narrow § 922(g)(1) when interstate nexus shown)
United States v. Podolsky, 798 F.2d 177 (7th Cir. 1986) (prosecutorial discretion in concurrent jurisdiction cases not judicially reviewable)
United States v. Skoczen, 405 F.3d 537 (7th Cir. 2005) (reverse sting allowed; notes possible differences if local purchase desired)
United States v. Humphreys, 468 F.3d 1051 (7th Cir. 2006) (minimal interstate nexus satisfied when gun manufactured outside state)
United States v. Castor, 937 F.2d 293 (7th Cir. 1991) (interstate history as predicate for federal authority; defendant need not know nexus)
United States v. Doherty, 17 F.3d 1056 (7th Cir. 1994) (plea-based preservation of pretrial rulings; scope of waiver)
United States v. Cain, 155 F.3d 840 (7th Cir. 1998) (waiver/jurisdiction distinction; limited waiver context)