United States v. Zavien Canada, 123 F.4th 159

Zavien Lenoy Canada was convicted by a jury for violating 18 U.S.C. § 922(g)(1), the federal felon-in-possession offense.
On appeal, Canada challenged both the constitutionality of § 922(g)(1) and the application of the Armed Career Criminal Act (ACCA) to enhance his sentence.
The district court counted a South Carolina criminal domestic violence conviction as a "violent felony" under the ACCA, resulting in an enhanced sentence.
Canada's facial challenge to § 922(g)(1) followed significant developments in Second Amendment law post-Bruen.
The panel included Chief Judge Diaz, Judge Harris, and Judge Heytens (author of the opinion), and the decision was to vacate and remand the sentence for resentencing.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Is § 922(g)(1) facially unconstitutional under the Second Amendment?	Canada: The statute is unconstitutional in all applications ("root and branch").	U.S.: The statute is constitutional and has a legitimate sweep.	Statute is facially constitutional.
Was the district court correct to sentence Canada under the ACCA, treating his prior SC conviction as a violent felony?	Canada: The conviction does not qualify due to lower intent requirement.	U.S.: Previous Fourth Circuit precedent treated it as a violent felony.	Precedent abrogated; conviction not a violent felony under ACCA; sentence vacated.

Greer v. United States, 593 U.S. 503 (relevant precedent on § 922(g)(1))
New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (set new framework for Second Amendment analysis)
District of Columbia v. Heller, 554 U.S. 570 (defined core Second Amendment rights)
Borden v. United States, 593 U.S. 420 (mens rea of recklessness insufficient under ACCA)
Washington State Grange v. Washington State Republican Party, 552 U.S. 442 (facial challenge standard)