United States v. Talbot, 23-8025

Lance James Talbot was charged with being a felon in possession of ammunition under 18 U.S.C. § 922(g)(1).
Talbot moved to dismiss the indictment, contending that § 922(g) was unconstitutional both on its face and as applied, in light of New York State Rifle & Pistol Ass’n v. Bruen.
The district court denied Talbot's motion; he entered a conditional guilty plea, preserving his right to appeal.
The Tenth Circuit initially affirmed the district court, noting its prior decision in Vincent v. Garland (“Vincent I”) foreclosed Talbot’s arguments, but he preserved the issue for further review.
The Supreme Court later vacated Vincent I and the Tenth Circuit's decision in Talbot’s case, remanding both for reconsideration after United States v. Rahimi.
On remand, the Tenth Circuit reaffirmed its position in Vincent v. Bondi (“Vincent III”), again upholding the constitutionality of § 922(g)(1), leading to the affirmation of the district court's judgment in Talbot’s case.

Issue	Talbot's Argument	United States' Argument	Held
Constitutionality of § 922(g)(1)	Section is unconstitutional under Bruen, facially and as applied	Section is constitutional, per Tenth Circuit precedent	Statute is constitutional; claims foreclosed by precedent

New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (Second Amendment standard clarified regarding firearms regulation)
United States v. Rahimi, 602 U.S. 680 (addressed application of Second Amendment to § 922(g) restrictions)