United States v. Duane Jackson

Court of Appeals for the Third Circuit·Decided July 29, 2026·No. 24-3293·Unpublished

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________

No. 24-3293 _______________

UNITED STATES OF AMERICA

v.

DUANE JACKSON, a/k/a Weez, a/k/a Weezy, Appellant _______________

On Appeal from the United States District Court for the Western District of Pennsylvania (D.C. No. 2:22-cr-00018-002) District Judge: Honorable William S. Stickman IV _______________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) February 12, 2026 _______________

Before: CHAGARES, Chief Judge, SCIRICA * and McKEE, Circuit Judges.

(Opinion Filed: July 29, 2026) _______________

OPINION ** _______________

* The Honorable Anthony J. Scirica was unavailable to participate in the decision in this case after submission to the merits panel. This opinion is filed by a quorum of the panel pursuant to 28 U.S.C. § 46(d) and 3d Cir. I.O.P. 12.1(b). ** This disposition is not an opinion of the full Court and, pursuant to 3d Cir. I.O.P. 5.7, does not constitute binding precedent. CHAGARES, Chief Judge.

Duane Jackson challenges his convictions for possession of a firearm as a felon

and conspiracy to make false statements in connection with the acquisition of firearms

under the Second Amendment, the Commerce Clause, and on several other bases. For

the following reasons, we will affirm.

I.

We write primarily for the parties and so recite only the facts essential to our

decision.

In 2015, Jackson pled guilty in the United States District Court for the Western

District of Pennsylvania to conspiracy to commit bank fraud in violation of 18 U.S.C. §

1349 and was sentenced to 18 months of incarceration, followed by three years of

supervised release. His term of supervised release commenced in 2017. It was revoked

in 2019 after Jackson committed multiple violations, including two instances in which he

led police on high-speed car chases while he had small children in his car. The District

Court sentenced Jackson to six months of imprisonment, followed by another two years

of supervised release. Jackson additionally pled guilty in state court to child

endangerment and other offenses arising from this same conduct and was sentenced by

the state court to 11 months and 29 days to 1 year, 11 months, and 28 days of

incarceration, followed by four years of probation.

Jackson was once again released to begin his federal term of supervised release

and state term of probation in April 2020. By April 2021, however, he and two other

men — John Moon and Donald Ware, Jr. — began a conspiracy to make straw purchases

2 of firearms from gun shops. Under their scheme, Moon and Ware would represent that

they were the true purchasers when those guns were, in fact, going to Jackson who was

prohibited from possessing them due to his felon status.

Once the scheme was discovered, Jackson was indicted in the United States

District Court for the Western District of Pennsylvania on five counts, including one

count of conspiracy to make false statements in association with the acquisition of a

firearm in violation of 18 U.S.C. §§ 371 and 922(a)(6), and four counts of felon in

possession of a firearm in violation of 18 U.S.C. § 922(g)(1). Jackson subsequently

moved to dismiss the indictment, arguing that §§ 922(a)(6) and (g)(1) violated the Second

Amendment and Commerce Clause, and were unconstitutionally vague. The District

Court denied the motion. Jackson consequently entered into a plea agreement in which

he agreed to plead guilty to one count of conspiracy to make false statements in

association with the acquisition of a firearm and two counts of felon in possession. In

doing so, Jackson waived his right to appeal, save for those issues raised in his motion to

dismiss. The District Court accepted the plea, and imposed a sentence of 120 months of

incarceration, followed by three years of supervised release. Jackson timely appealed.

II. 1

Jackson challenges his convictions under the Second Amendment, the Commerce

1 The District Court had jurisdiction pursuant to 18 U.S.C. § 3231. We have jurisdiction pursuant to 28 U.S.C. § 1291 and 18 U.S.C. § 3742(a). When reviewing a motion to dismiss the indictment, we review the District Court’s factual findings for clear error and its legal conclusions de novo. See United States v. Harris, 144 F.4th 154, 157 (3d Cir. 2025); United States v. Stock, 728 F.3d 287, 291 (3d Cir. 2013).

3 Clause, and on several other bases. We consider each in turn.

A.

Jackson first asserts an as-applied Second Amendment challenge, contending that

his prior disqualifying felonies — conspiracy to commit bank fraud and firearm

possession — are non-violent offenses that do not justify disarming him under

§ 922(g)(1) and that the false statements of his co-defendant, Donald Ware Jr., about the

true buyer of the firearms are therefore immaterial under § 922(a)(6) as Jackson was not

truly prohibited from purchasing the firearms. These arguments, however, are foreclosed

by our precedent which provides that the Second Amendment right to possess firearms

does not extend to those, like Jackson, who were on federal supervised release or state

probation at the time of the underlying conduct. See United States v. Moore, 111 F.4th

266, 273 (3d Cir. 2024) (“A convict completing his sentence on supervised release does

not have a Second Amendment right to possess a firearm.”); United States v. Quailes,

126 F.4th 215, 223 (3d Cir. 2025) (“Because parolees and probationers—like convicts on

federal supervised release—are still serving their sentences, the Second Amendment

affords them no protection.”); see also Jackson Br. 26 (“This holding in Moore arguably

applies to Mr. Jackson.”). We will therefore affirm Jackson’s convictions on this basis.

B.

Jackson separately challenges our method of evaluating as-applied Second

Amendment challenges to § 922(g)(1) pursuant to Range v. Attorney General, 124 F.4th

218 (3d Cir. 2024) (en banc) and Pitsilides v. Barr, 128 F.4th 203 (3d Cir. 2025).

According to Jackson, this test is an “ill-defined dangerousness inquiry” which violates

4 the Fifth Amendment, Sixth Amendment, separation of powers doctrine, and Due Process

Clause by: (1) judicially re-writing § 922(g)(1) to “include an extra-textual

dangerousness element;” (2) permitting judges, rather than juries, to find this new

element; and (3) sanctioning an unbounded and speculative inquiry into a “defendant’s

risk of danger based on his past.” Jackson Br. 11, 23. We disagree.

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