United States v. Steven Dotson, 712 F.3d 369

Defendant arrested after allegedly assaulting a woman and pointing a pistol; charged with being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
Convicted in a bench trial and sentenced to 188 months' imprisonment.
On appeal, issue is whether the pistol qualifies as a firearm under 18 U.S.C. § 921(a)(3)(A)-(B), defined as a weapon that will or may readily be used to expel a projectile by explosive action, or the frame or receiver.
The Hi-Point .380 pistol was inoperable at the time due to extensive damage, corrosion, and missing parts; expert testimony confirmed it could not expel a projectile currently and would require repair to restore functionality.
The government conceded it could not expel a projectile at possession nor be readily converted to do so; restoration would take 1–2 hours for an expert, longer for a novice.
The district judge held the gun was designed to expel a projectile; the court rejected extremes: (i) ‘once a gun, always a gun’ and (ii) that a severely damaged gun ceases to be a weapon; concluded the gun fits the statutory definition and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ‘is designed’ requires current operability.	Defendant: design is altered by damage; not a weapon.	Alternatively, a damaged gun not repairable cannot be designed to expel.	No; design remains despite damage; weapon fits definition.

United States v. Rivera, 415 F.3d 284 (2d Cir. 2005) (design vs. object; not redesignated by damage)
United States v. Yannott, 42 F.3d 999 (6th Cir. 1994) (design concept in firearm status)
United States v. TRW Rifle, 7.62x51mm Caliber, One Model 14, 447 F.3d 686 (9th Cir. 2006) (illustrates design vs. condition considerations)