United States v. Eibe Scott

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 17, 2026
Docket25-12828
StatusUnpublished

This text of United States v. Eibe Scott (United States v. Eibe Scott) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Eibe Scott, (11th Cir. 2026).

Opinion

USCA11 Case: 25-12828 Document: 17-1 Date Filed: 04/17/2026 Page: 1 of 7

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12828 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

EIBE SCOTT, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Alabama D.C. Docket No. 1:23-cr-00233-ECM-JTA-1 ____________________

Before JILL PRYOR, NEWSOM, and BRANCH, Circuit Judges. PER CURIAM: Eibe Scott, proceeding pro se, appeals his convictions for possession of a firearm and ammunition by a convicted felon. He USCA11 Case: 25-12828 Document: 17-1 Date Filed: 04/17/2026 Page: 2 of 7

2 Opinion of the Court 25-12828

argues that 18 U.S.C. § 922(g)(1) is unconstitutional under the Sec- ond Amendment as applied to him and that our decision in United States v. Dubois (Dubois II), 139 F.4th 887 (11th Cir.), petition for cert. filed, (No. 25-6281) (U.S. Dec. 4, 2025), was wrongly decided. The government responds by moving for summary affirmance. Summary disposition is appropriate either where time is of the essence, such as “situations where important public policy is- sues are involved or those where rights delayed are rights denied,” or where “the position of one of the parties is clearly right as a mat- ter of law so that there can be no substantial question as to the out- come of the case, or where, as is more frequently the case, the ap- peal is frivolous.” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). We review a challenge to the constitutionality of a statute de novo. United States v. Ostrander, 114 F.4th 1348, 1359 (11th Cir. 2024). We have explained that “because a factual, as-applied chal- lenge ‘asserts that a statute cannot be constitutionally applied in particular circumstances, it necessarily requires the development of a factual record for the court to consider.’” Schultz v. Alabama, 42 F.4th 1298, 1319 (11th Cir. 2022) (quoting Harris v. Mexican Spe- cialty Foods, Inc., 564 F.3d 1301, 1308 (11th Cir. 2009)). “This is be- cause an as-applied challenge ‘addresses whether a statute is uncon- stitutional on the facts of a particular case or to a particular party.’” Id. (quoting Harris, 564 F.3d at 1308). USCA11 Case: 25-12828 Document: 17-1 Date Filed: 04/17/2026 Page: 3 of 7

25-12828 Opinion of the Court 3

The Second Amendment protects the right to keep and bear arms. U.S. Const. amend. II. The federal felon-in-possession stat- ute prohibits anyone who has been convicted of “a crime punisha- ble by imprisonment for a term exceeding one year” from keeping a firearm or ammunition. 18 U.S.C. § 922(g)(1). In Heller, the Supreme Court held that the District of Colum- bia’s total ban on handgun possession, including possession in the home, violated the Second Amendment. D.C. v. Heller, 554 U.S. 570, 574-76, 628, 635 (2008). The Court noted that the Second Amendment right to bear arms is “not unlimited” and that while it “[did] not undertake an exhaustive historical analysis . . . of the full scope of the Second Amendment, nothing in [its] opinion should [have been] taken to cast doubt on longstanding prohibitions on the possession of firearms by felons.” Id. at 581, 626. Following Heller, the courts of appeals largely adopted a two-step framework for Second Amendment challenges in which they, first, considered whether a law regulated activity within the scope of the Amend- ment based on its original historical meaning and, second, applied a means-end scrutiny test to determine the law’s validity. See Bruen, 597 U.S. at 18-19. In Rozier, we held that § 922(g)(1) was constitutional, “even if a felon possesses a firearm purely for self-defense.” United States v. Rozier, 598 F.3d 768, 770 (11th Cir. 2010). The Rozier decision did not rely on means-end scrutiny to conclude that § 922(g)(1) was constitutional, but rather, recognized that prohibiting felons from USCA11 Case: 25-12828 Document: 17-1 Date Filed: 04/17/2026 Page: 4 of 7

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possessing firearms was a “‘presumptively lawful longstanding pro- hibition.’” Id. at 771 (quoting United States v. White, 593 F.3d 1199, 1205-06 (11th Cir. 2010)). We highlighted “that ‘nothing in [Heller] should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons’” or “suggest[ed] that statutes dis- qualifying felons from possessing a firearm under any and all cir- cumstances do not offend the Second Amendment.” Id. (quoting Heller, 554 U.S. at 2816-17). We concluded that Rozier’s purpose for possessing a firearm, and the fact that the firearm was con- strained to his home, was immaterial because felons as a class could be excluded from firearm possession. Id. In Bruen, the Supreme Court reversed the dismissal of a civil suit under 42 U.S.C. § 1983 brought by applicants who had been denied unrestricted licenses to carry a handgun in public that chal- lenged New York regulations requiring all citizens to demonstrate “proper cause” to obtain concealed carry licenses as violating their Second and Fourteenth Amendment rights. See New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1, 8-16, 31 (2022). The Su- preme Court reasoned that reliance on means-end analysis in the Second Amendment context was inconsistent with “Heller’s meth- odology [that] centered on constitutional text and history.” Id. at 16-24. The Supreme Court announced the appropriate standard for Second Amendment analysis: (1) “[w]hen the Second Amend- ment’s plain text covers an individual’s conduct, the Constitution presumptively protects that conduct”; and (2) if the conduct is pre- sumptively protected, “[t]he government must then justify its reg- USCA11 Case: 25-12828 Document: 17-1 Date Filed: 04/17/2026 Page: 5 of 7

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ulation by demonstrating that it is consistent with the Nation’s his- torical tradition of firearm regulation.” Id. at 19, 24. In Bruen, as it did in Heller, the Supreme Court referenced the Second Amend- ment rights of “law-abiding, responsible citizens.” Id. at 26, 38 n.9, 70; Heller, 554 U.S. at 635. In our initial panel decision in Dubois, we rejected a defend- ant’s Second Amendment challenge to § 922(g)(1) under Bruen on the ground that Bruen did not abrogate Rozier, which relied on Hel- ler, and that we remained bound by Rozier. United States v. Dubois (Dubois I), 94 F.4th 1284, 1291-93 (11th Cir. 2024), cert. granted and judgment vacated sub nom., Dubois v. United States, 145 S. Ct. 1041 (2025), and reinstated by, Dubois II, 139 F.4th 887 (11th Cir. 2025). In United States v. Rahimi, 602 U.S. 680

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Related

United States v. Archer
531 F.3d 1347 (Eleventh Circuit, 2008)
Harris v. Mexican Specialty Foods, Inc.
564 F.3d 1301 (Eleventh Circuit, 2009)
United States v. White
593 F.3d 1199 (Eleventh Circuit, 2010)
United States v. Rozier
598 F.3d 768 (Eleventh Circuit, 2010)
District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
United States v. Andre Michael Dubois
94 F.4th 1284 (Eleventh Circuit, 2024)
United States v. Rahimi
602 U.S. 680 (Supreme Court, 2024)
United States v. Matthew Ostrander
114 F.4th 1348 (Eleventh Circuit, 2024)
United States v. Andre Michael Dubois
139 F.4th 887 (Eleventh Circuit, 2025)

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United States v. Eibe Scott, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-eibe-scott-ca11-2026.