United States v. William Chester, Jr.
514 F. App'x 393
4th Cir.2013Background
- Chester appeals his guilty plea and conviction for possession of firearms in violation of 18 U.S.C. § 922(g)(9) after a misdemeanor domestic violence conviction.
- This Court previously held in Chester II that intermediate scrutiny applies to § 922(g)(9) challenges and remanded for evidence of a substantial relationship to a government goal.
- On remand, the district court held § 922(g)(9) survives intermediate scrutiny based on Staten’s reasoning.
- Chester challenged the district court’s application of the standard and the statute’s relation to government objectives, including overbreadth.
- We review the district court’s Second Amendment ruling de novo and ultimately affirm.
- The opinion states the same items as Staten and applies Chester II precedent to conclude the statute satisfies the proper standard and is not overbroad.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Level of scrutiny applied | Chester | Chester | Intermediate scrutiny governs § 922(g)(9) |
| Substantial relation to government goal | Chester contends no substantial relation | Staten supports substantial relation | Court adopts Staten's substantial relation finding |
| Overbreadth challenge | Chester claims overbreadth | No circuit accepts overbreadth in this context | Overbreadth challenge rejected |
Key Cases Cited
- United States v. Staten, 666 F.3d 154 (4th Cir. 2011) (upheld § 922(g)(9) as reasonably related to a substantial government objective)
- United States v. Chester, 628 F.3d 673 (4th Cir. 2010) (established intermediate scrutiny as the standard for § 922(g)(9) challenges)
- United States v. Masciandaro, 638 F.3d 458 (4th Cir. 2011) (overbreadth challenges not accepted in Second Amendment context)