United States v. Artie Byrd

Court of Appeals for the D.C. Circuit·Decided August 26, 2026·No. 24-3048·Unpublished

Opinion

United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 24-3048 September Term, 2025 FILED ON: AUGUST 26, 2026

ARTIE BYRD, APPELLANT

v.

UNITED STATES OF AMERICA, APPELLEE

On Appeal from the United States District Court for the District of Columbia (No. 1:22-cr-00309-1)

Before: KATSAS and PAN, Circuit Judges, and GINSBURG, Senior Circuit Judge.

JUDGMENT

This appeal was considered on the record from the United States District Court for the District of Columbia and on the briefs and oral argument of the parties. The court has afforded the issues full consideration and has determined that they do not warrant a published opinion. See D.C. Cir. R. 36(d). For the reasons stated below, it is:

ORDERED and ADJUDGED that the judgment of the district court be AFFIRMED.

* * *

A jury convicted Appellant Artie Byrd of being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). The district court sentenced him to 72 months’ imprisonment, followed by 36 months of supervised release. On appeal, Byrd seeks reversal of his conviction and remand for a new trial or, alternatively, remand for resentencing. He challenges the constitutionality of his conviction, the district court’s restriction on the scope of closing arguments, and the reasonableness of his above-Guidelines sentence. Discerning no error, we affirm.

I.

In September 2022, two police officers in a patrol car observed Byrd in a car with counterfeit license plates. When they followed him, Byrd crashed his car into a bench and then ran. The officers eventually detained him and recovered a firearm. At that time, Byrd was serving a term of supervised release for his second felon-in-possession conviction. A grand jury indicted Byrd on one count of unlawful possession of a firearm by a convicted felon in violation of 18 U.S.C. § 922(g)(1). Byrd moved to dismiss the indictment on the ground that § 922(g)(1) violated his right to bear arms under the Second Amendment. The district court denied the motion, and trial proceeded.

During opening statements, Byrd’s counsel argued that, on the day of Byrd’s arrest, he was “a Black man in a predominantly white part of D.C. who[] [was] about to be stopped by the police, and he[] [was] scared because of so many traffic stops that have gone wrong where unarmed Black men have been killed.” App. 139. Byrd did not testify at trial. Thus, before closing argument, the district court ordered Byrd’s counsel to refrain from arguing that Byrd feared the police because counsel had not presented “any admissible evidence” to support that assertion. App. 550. The jury found Byrd guilty.

Over Byrd’s objection, the district court imposed a 72-month sentence, which reflected an upward variance from Byrd’s Sentencing Guidelines range of 41 to 51 months. The district court considered “several aggravating characteristics” in Byrd’s criminal history, including a 2019 charge of accessory-after-the-fact to assault with intent to kill while armed (AWIK). App. 679. Although a jury acquitted Byrd of the charge during the pendency of the instant case, the district court reviewed the AWIK case’s record and found that Byrd committed the accessory offense by a preponderance of the evidence.

In the AWIK case, Jermaine Chambers reported to the police that his coworkers — Dominic Copeland and “A.R.” — robbed him and shot him in 2019. Chambers twice identified Byrd as A.R. when shown a photo of Byrd’s driver’s license — he made one identification on the day after the shooting, and another when he testified before the grand jury. Chambers also saw the two perpetrators driving a white Toyota Camry at the scene of the shooting. An eyewitness who observed the shooting reported that car’s license plate information to 911. Law enforcement traced the car to its owner, Erik Rubio, who was a friend of Byrd. Rubio testified that he lent his car to A.R. on the day of the shooting. At trial in 2023, Chambers testified that he did not “want to get on th[e] stand.” App. 909. When asked about the reason for his reluctance to testify, he expressed that “I don’t do that . . . in my community . . . .” Id. Chambers did not make an in-court identification of Byrd as A.R., but he testified that, in 2019, A.R. had “long” hair and “dreads.” App. 881. Photos of Byrd from the relevant timeframe confirmed that he had dreads in 2019. The district court concluded that “significant evidence” established that Byrd was A.R. App. 682.

Byrd timely appeals his conviction and sentence. We have jurisdiction under 28 U.S.C.

§ 1291 and 18 U.S.C. § 3742.

II.

We review the district court’s denial of a motion to dismiss the indictment de novo. United States v. Verrusio, 762 F.3d 1, 13 (D.C. Cir. 2014). We review the district court’s decision to limit the scope of closing argument for abuse of discretion. United States v. Borda, 848 F.3d 1044, 1062 (D.C. Cir. 2017). As for a sentencing decision, we review legal questions de novo and factual findings for clear error, United States v. Mohammed, 89 F.4th 158, 161–62 (D.C. Cir. 2023), and we apply a “deferential abuse-of-discretion” standard to assess the reasonableness of the sentence, Gall v. United States, 552 U.S. 38, 41 (2007).

III.

Byrd challenges his conviction and his sentence. First, he argues that the statute under which he was convicted, 18 U.S.C. § 922(g)(1), is unconstitutional. Second, he argues that the district court’s limitation on the scope of his closing argument prevented him from rebutting the government’s case. Third, he claims the district court procedurally erred and rendered a substantively unreasonable sentence. We are unpersuaded on all counts.

A.

Byrd was convicted of being a felon in possession of a firearm, in violation of 18 U.S.C.

§ 922(g)(1). He contends that the statute violates the Second Amendment — both facially and as applied to him.

The Second Amendment right to possess firearms “is not unlimited,” and “longstanding prohibitions on the possession of firearms by felons” remain “presumptively lawful . . . .” District of Columbia v. Heller, 554 U.S. 570, 626–27, 627 n.26 (2008). When a firearm regulation is challenged, we assess its constitutionality using a two-step approach. New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1, 24 (2022). First, we examine whether “the Second Amendment’s plain text covers an individual’s conduct.” Id. at 17. If so, then the Second Amendment presumptively protects such conduct, and we proceed to the second step. At the second step, the government bears the burden of “justify[ing] its regulation by demonstrating that” the challenged law — in this case, § 922(g)(1) — “is consistent with the Nation’s historical tradition of firearm regulation.” Id. at 24.

Here, the parties agree that the Second Amendment’s plain text covers Byrd’s possession of a firearm, and that Byrd is among “the people” protected by the Second Amendment. Bruen, 597 U.S. at 32. The burden therefore shifts to the government to demonstrate that its regulation is consistent with the Nation’s historical tradition of firearm regulation. The government readily meets that test because Byrd was on supervised release for a felony offense when he committed the instant offense. Section 922(g)(1) is constitutional as applied to Byrd because our Nation has a historical tradition of requiring felons to forfeit their firearms while serving their sentences. United States v. Richardson, No. 24-3151, 2026 WL 2451537, at *3–4 (D.C. Cir. Aug. 21, 2026) (precedential opinion). And because § 922(g)(1) is constitutional as applied to Byrd, we need not address the merits of his facial challenge — he cannot “establish that no set of circumstances exists under which the [statute] would be valid.” United States v. Rahimi, 602 U.S. 680, 693 (2024)

(quoting United States v. Salerno, 481 U.S. 739, 745 (1987)); see also id. at 701 & n.2. We therefore affirm Byrd’s § 922(g)(1) conviction.

B.

Byrd next challenges the district court’s decision to limit his counsel’s closing argument.

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