United States v. Garrick Richardson

Summary

The court affirmed the denial of Richardson’s motion to dismiss, holding that 18 U.S.C. § 922(g)(1) is constitutional as applied to a felon who possessed a firearm while still serving a criminal sentence through non-custodial supervision. Applying the text-and-history framework, the court found a widespread historical tradition of temporarily disarming convicted felons during imprisonment, probation, parole, or comparable supervision. Because the statute was constitutional in Richardson’s circumstances, the court also rejected his facial challenge.