United States v. Jared Boyle

• Court: Court of Appeals for the Eleventh Circuit
• Decided: September 29, 2025
• Docket: 24-10744
• Status: Unpublished

Opinion

USCA11 Case: 24-10744 Document: 43-1 Date Filed: 09/29/2025 Page: 1 of 3

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-10744 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

JARED BOYLE, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 5:23-cr-00098-TPB-PRL-1 ____________________

Before BRANCH, KIDD, and ANDERSON, Circuit Judges. PER CURIAM: Jared Boyle pleaded guilty to committing controlled sub- stance and firearm offenses and was sentenced to 120 months of imprisonment. He now appeals only his conviction under 18 U.S.C. USCA11 Case: 24-10744 Document: 43-1 Date Filed: 09/29/2025 Page: 2 of 3

2 Opinion of the Court 24-10744

§ 922(g)(1), which criminalizes possession of a firearm by an indi- vidual previously convicted of a crime punishable by more than one year in prison. Boyle argues that this statute is unconstitutional under the Second Amendment and the Commerce Clause, but we review these challenges only for plain error, as they are raised for the first time on appeal. United States v. Wright, 607 F.3d 708, 715 (11th Cir. 2010). Because Boyle’s arguments are foreclosed by bind- ing precedent, we conclude that he cannot show error, plain or oth- erwise, and affirm his conviction. Boyle first argues that § 922(g) is unconstitutional under the Second Amendment, both facially and as applied to him, consider- ing New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 142 S. Ct. 2111 (2022), and United States v. Rahimi, 144 S. Ct. 1889 (2024). He con- tends that his conduct is covered under the Second Amendment and that the government cannot show a tradition of convicted fel- ons never being permitted to possess firearms or ammunition. However, we recently confirmed that neither Rahimi nor Bruen ab- rogated our previous decision in United States v. Rozier, 598 F.3d 768, 770–71 (11th Cir. 2010), which held that § 922(g)(1) is constitu- tional under the Second Amendment. United States v. Dubois, 139 F.4th 887, 890–94 (11th Cir. 2025). Boyle further argues that § 922(g)(1) exceeds Congress’s au- thority under the Commerce Clause. He contends that United States v. Lopez, 514 U.S. 549 (1995), and United States v. Morrison, 529 U.S. 598 (2000), render the statute facially unconstitutional, as it does not ensure that possession, a non-economic activity, USCA11 Case: 24-10744 Document: 43-1 Date Filed: 09/29/2025 Page: 3 of 3

24-10744 Opinion of the Court 3

substantially affects interstate commerce. However, “we have al- ready held that § 922(g) is within Congress’s Commerce Clause Powers.” United States v. Stancil, 4 F.4th 1193, 1200 (11th Cir. 2021); see United States v. Scott, 263 F.3d 1270, 1273–74 (11th Cir. 2001). Boyle further asserts that the government did not establish a connection between his firearm possession and interstate or for- eign commerce. But we have rejected similar as-applied challenges and determined that the government can prove the required “min- imal nexus” by showing that a firearm was manufactured outside the state where the offense took place and thus “necessarily trav- eled in interstate commerce.” Wright, 607 F.3d at 715–16; see United States v. McAllister, 77 F.3d 387, 390 (11th Cir. 1996). That burden was satisfied in this case because, when pleading guilty, Boyle ad- mitted that his firearm was manufactured in Brazil but recovered in Florida. Wright, 607 F.3d at 715–16. Because “we are bound to follow our prior binding prece- dent unless and until it is overruled by this Court en banc or by the Supreme Court,” Boyle’s Second Amendment and Commerce Clause challenges must fail. United States v. White, 837 F.3d 1225, 1228 (11th Cir. 2016) (citation modified); see United States v. Lejarde-Rada, 319 F.3d 1288, 1291 (11th Cir. 2003) (“[T]here can be no plain error where there is no precedent from the Supreme Court or this Court directly resolving it.”). Accordingly, we AFFIRM Boyle’s § 922(g)(1) conviction.