United States v. Williams
5:25-cr-00079
W.D. La.Jun 17, 2025Background
- Leon Williams was arrested on July 22, 2024, for unlawful possession of firearms and a machinegun, and later indicted for possession of a firearm by a convicted felon and illegal possession of a machine gun.
- Williams has multiple prior felony convictions, including drug, burglary, and firearms offenses.
- Williams filed a pretrial motion to dismiss Count 1, arguing that 18 U.S.C. § 922(g)(1) (felon-in-possession) is unconstitutional as applied to him under the Second Amendment.
- The Government opposed, arguing that longstanding historical tradition supports disarming individuals with Williams' criminal history and that drugs and guns are a dangerous combination.
- The district court reviewed the challenge based on the Supreme Court’s Bruen framework and relevant Fifth Circuit precedent, focusing on whether tradition justifies firearms dispossession for people with analogous criminal histories.
Issues
| Issue | Williams' Argument | Government's Argument | Held |
|---|---|---|---|
| Constitutionality of § 922(g)(1) as-applied | Statute violates his Second Amendment rights unless Gov't proves tradition of disarming someone like him | Williams is a "dangerous" person; tradition supports disarming felons with these crimes | § 922(g)(1) constitutional as-applied to Williams |
| Applicability of Second Amendment | Felons are among "the people" protected by Second Amendment | Only law-abiding citizens are protected; felons may be excluded | Felons are covered, but can be regulated |
| Historical tradition requirement (under Bruen) | No historical tradition of disarming people with his criminal record | History contains sufficient analogues in Founding-era laws for felons with similar or related offenses | Government met burden to show historical analogue |
| Relevance of specific crimes (drugs, burglary, firearms) | History doesn't specifically ban drug possession | Founding-era laws punished burglary, theft, and related acts severely, including disarmament | Specific historical twins not required; sufficient analogues exist |
Key Cases Cited
- District of Columbia v. Heller, 554 U.S. 570 (2008) (recognized individual Second Amendment right with limits)
- New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 597 U.S. 1 (2022) (established two-step framework for Second Amendment challenges based on history and tradition)
- United States v. Rahimi, 602 U.S. 588 (2024) (upheld firearm dispossession law for those posing physical safety threats)
- United States v. Diaz, 116 F.4th 458 (5th Cir. 2024) (clarifies application of historical tradition analysis for felon firearm prohibitions)
- Smith v. United States, 508 U.S. 223 (1993) (court notes drug offenses and firearms are a dangerous combination)
- United States v. Jackson, 110 F.4th 1120 (8th Cir. 2024) (upheld as-applied constitutionality of § 922(g)(1) for drug convictions)