United States v. Mario Martinez Williams

• Court: Court of Appeals for the Eleventh Circuit
• Decided: February 20, 2026
• Docket: 25-11358
• Status: Unpublished

Opinion

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NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-11358 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus

MARIO MARTINEZ WILLIAMS, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 9:24-cr-80114-AMC-1 ____________________

Before LUCK, LAGOA, and MARCUS, Circuit Judges. PER CURIAM: Mario Williams appeals his conviction for being a felon in possession of a firearm, arguing that the district court erred in denying his motion to dismiss his indictment because: (1) 18 U.S.C. USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 2 of 10

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§ 922(g)(1) is unconstitutional under the Second Amendment, as applied to him, under New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022), and United States v. Rahimi, 602 U.S. 680 (2024); (2) our decision in United States v. Dubois (Dubois II), 139 F.4th 887 (11th Cir. 2025), cert. denied, 2026 WL 135685 (U.S. Jan. 20, 2026) (No. 25-6281), is inconsistent with our earlier ruling in NRA v. Bondi, 133 F.4th 1108 (11th Cir. 2025) (en banc), petition for cert. filed, 2025 WL 1458530 (U.S. May 20, 2025) (No. 24-1185); and (3) under the prior-panel-precedent rule, Bondi controls and his constitutional challenge to § 922(g)(1) must be considered under Bruen/Rahimi’s framework. The government has moved for sum- mary affirmance. After careful review, we grant the government’s motion and summarily affirm. Summary disposition is appropriate either where time is of the essence, including “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 . . . the appeal is frivolous.” Groendyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). 1 We gen- erally review challenges to the constitutionality of a statute de novo. United States v. Gruezo, 66 F.4th 1284, 1292 (11th Cir. 2023).

1 In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc), we

adopted as binding precedent all Fifth Circuit decisions issued before October 1, 1981. USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 3 of 10

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The Second Amendment reads: “A well regulated Militia, being necessary to the security of a free State, the right of the peo- ple to keep and bear Arms, shall not be infringed.” U.S. Const. amend. II. The federal felon-in-possession statute prohibits anyone who has been convicted of “a crime punishable by imprisonment for a term exceeding one year” from “possess[ing] in or affecting commerce, any firearm or ammunition.” 18 U.S.C. § 922(g)(1). In District of Columbia v. Heller, 554 U.S. 570 (2008), the Su- preme Court held that the District of Columbia’s total ban on handgun possession, including possession in the home, violated the Second Amendment. Id. at 574–76, 628, 635. The Supreme Court stated that the Second Amendment right to bear arms presump- tively “belongs to all Americans,” but is not unlimited. Id. at 581, 626. The Supreme Court noted in Heller that while it “[did] not undertake an exhaustive historical analysis . . . of the full scope of the Second Amendment, nothing in [the Heller] opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons.” Id. Courts of appeals adopted a “two-step” framework for assessing Second Amendment challenges following Heller: (1) determine whether the law in question regulates activity within the scope of the right to bear arms based on its original his- torical meaning; and (2) if so, apply means-end scrutiny to test the law’s validity. Bruen, 597 U.S. at 18–19. In United States v. Rozier, 598 F.3d 768 (11th Cir. 2010), de- cided between Heller and Bruen, we relied on Heller in holding that § 922(g)(1) did not violate the Second Amendment, “even if a felon USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 4 of 10

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possesses a firearm purely for self-defense.” Id. at 770. Our deci- sion did not rely on means-end scrutiny to conclude that § 922(g)(1) was constitutional; instead, we recognized that prohibiting felons from possessing firearms was a “presumptively lawful longstand- ing prohibition.” Id. at 771 (citation modified). We highlighted “that ‘nothing in [Heller] should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons’” or “suggest[] that statutes disqualifying felons from possessing a firearm under any and all circumstances do not offend the Second Amendment.” Id. (quoting Heller, 554 U.S. at 626–27). We con- cluded that Rozier’s purpose for possessing a firearm, and the fact that the firearm was constrained to his home, was immaterial be- cause 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 597 U.S. at 8–16, 31. The Supreme Court reasoned that reliance on means-end anal- ysis in the Second Amendment context was inconsistent with “Hel- ler’s methodology [that] centered on constitutional text and his- tory.” Id. at 16–24. The Supreme Court announced the appropri- ate standard for Second Amendment analysis: (1) “[w]hen the Sec- ond Amendment’s plain text covers an individual’s conduct, the Constitution presumptively protects that conduct”; and (2) if the USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 5 of 10

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conduct is presumptively protected, “[t]he government must then justify its regulation by demonstrating that it is consistent with the Nation’s historical tradition of firearm regulation.” Id. at 17. The Supreme Court in Bruen, quoting Heller, referenced the Second Amendment rights of “law-abiding, responsible citizens.” Id. at 26, 38 n.9, 70 (quoting Heller, 554 U.S. at 636). In Rahimi, decided in June 2024, the Supreme Court held that § 922(g)(8), which prohibits the possession of firearms by indi- viduals subject to a domestic violence restraining order, did not fa- cially violate the Second Amendment because regulations prohib- iting individuals who pose a credible threat of harm to others from misusing firearms are part of our country’s historical tradition. 602 U.S. at 690–92, 699–700. The Supreme Court noted that courts had “misunderstood” the Bruen methodology and stated that the Sec- ond Amendment permitted not just regulations identical to those in existence in 1791, but also those regulations that are “consistent with the principles that underpin our regulatory tradition” and are “relevantly similar to laws that our tradition is understood to per- mit.” Id. at 691–92 (citation modified). The Supreme Court noted that the right to bear arms “was never thought to sweep indiscrim- inately” and extensively detailed the historical tradition of firearm regulations, including the prohibition of classes of individuals from firearm ownership. Id. at 691, 693–98. It again noted that prohibi- tions on felons’ possession of firearms are “presumptively lawful.” Id. at 699 (citation modified). It also explained that “[o]ur tradition of firearm regulation allows the Government to disarm individuals who present a credible threat to the physical safety of others.” Id. USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 6 of 10

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at 700. The Supreme Court held that § 922(g)(8) was constitutional as applied to Rahimi because the restraining order to which Rahimi was subject included a finding that he posed “a credible threat to the physical safety” of another, and the government provided “am- ple evidence” that the Second Amendment permitted “the disarma- ment of individuals who pose a credible threat to the physical safety of others.” Id. at 689, 693 (citation modified). Meanwhile, in United States v. Dubois (Dubois I), 94 F.4th 1284, 1291–93 (11th Cir. 2024), vacated, 145 S. Ct. 1041 (2025) (mem.), reinstated, Dubois II, 139 F.4th at 889, which was first de- cided before Rahimi, we had rejected a defendant’s Second Amend- ment challenge to § 922(g)(1) on the grounds that Bruen did not ab- rogate Rozier, which relied on Heller, so we remained bound by Rozier. Id. at 1291–93. The Supreme Court then vacated and re- manded Dubois I for reconsideration in light of Rahimi. 145 S. Ct. at 1041. While Dubois I’s remand was pending, we issued an en banc decision in Bondi, ruling that Florida’s law prohibiting the purchase of firearms by minors was not unconstitutional under the Second Amendment as applied to individuals between the ages of eight- een and twenty-one because it was consistent with our nation’s his- torical tradition of firearm regulation. 133 F.4th at 1111, 1117–30. In doing so, we cited Rahimi and Bruen to explain that “[w]hen a person challenges a law regulating arms-bearing conduct, courts must examine the historical tradition of firearm regulation in our nation to delineate the contours of the right.” Id. at 1114 (citation USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 7 of 10

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modified). We did not discuss § 922(g)(1) or Dubois I in Bondi. See generally id. On the Supreme Court’s remand of Dubois I, we concluded that Rahimi did not abrogate our “holding in Rozier that section 922(g)(1) is constitutional under the Second Amendment” and re- instated our previous opinion. Dubois II, 139 F.4th at 889. As we explained, “Rahimi continued to rely on Heller” and “Rahimi also did not abrogate Rozier.” Id. at 892–93. We concluded that we would “require clearer instruction from the Supreme Court before we may reconsider the constitutionality of section 922(g)(1),” so Rozier continued to bind us. Id. at 894. The majority’s decision in Dubois II did not cite or discuss Bondi. See id. In Florida Commissioner of Agriculture v. Attorney General, 148 F.4th 1307 (11th Cir. 2025), we concluded that the district court erred in concluding that two medical marijuana users had failed to state a claim in their as-applied Second Amendment challenge to 18 U.S.C. § 922(d)(3) and (g)(3), which prohibit “unlawful users” of controlled substances from being sold or possessing firearms. Id. at 1311, 1321 (citation modified). At Bruen’s first step, we con- cluded that the plaintiffs’ “conduct of attempting to purchase and possess firearms for self-defense purposes is clearly covered by the Second Amendment’s plain text” and that, “while there is a history and tradition in this Nation of disarming convicted felons, nothing in the [complaint] indicates that [the plaintiffs] have ever been con- victed of any crime” or had committed any crime beyond a misde- meanor. Id. at 1317. At Bruen’s second step, we similarly found USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 8 of 10

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that the government “ha[d] not pointed to any historical tradition of disarming those engaged in misdemeanant conduct,” that the plaintiffs had never been convicted of a felony, and that the plain- tiffs could not be considered dangerous people solely due to their use of medical marijuana. Id. at 1318–19. Significantly, we noted that the government “very well may prove at a later stage of litiga- tion . . . that Appellants can fairly be considered relevantly similar to felons . . . who can categorically be disarmed.” Id. at 1321 n.16 (citation modified). We cited Dubois II only in summarizing the government’s argument that the plaintiffs’ conduct was akin to fel- ons, who have historically been excluded from the right to bear arms. Id. at 1317. Under our prior-panel-precedent rule, “a prior panel’s hold- ing is binding on all subsequent panels unless and until it is over- ruled or undermined to the point of abrogation by the Supreme Court or by this [C]ourt sitting en banc.” United States v. Archer, 531 F.3d 1347, 1352 (11th Cir. 2008) (citation modified). “To over- rule or abrogate a prior panel’s decision, the subsequent Supreme Court or en banc decision must be clearly on point and must actu- ally abrogate or directly conflict with, as opposed to merely weaken, the holding of the prior panel.” United States v. Gillis, 938 F.3d 1181, 1198 (11th Cir. 2019) (citation modified). Abroga- tion requires the subsequent decision to “demolish and eviscerate all the fundamental props of the prior-panel precedent.” United States v. Lightsey, 120 F.4th 851, 860 (11th Cir. 2024) (citation modi- fied). USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 9 of 10

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We’ve “categorically rejected an overlooked reason or argu- ment exception to the prior-panel-precedent rule.” United States v. Jackson, 55 F.4th 846, 853 (11th Cir. 2022) (citation modified). We’ve recognized that “questions which merely lurk in the record, neither brought to the attention of the court nor ruled upon, are not to be considered as having been so decided as to constitute precedents.” Id. (citation modified). Regardless, we’ve stressed that a panel may not disregard precedent and, thus, that the prior- panel-precedent rule applies, even if a later panel believes it was wrongly decided. United States v. Golden, 854 F.3d 1256, 1257 (11th Cir. 2017) (per curiam) (citing Smith v. GTE Corp., 236 F.3d 1292, 1303 (11th Cir. 2001) (rejecting an exception to the prior-panel prec- edent rule “based upon a perceived defect in the prior panel’s rea- soning or analysis as it relates to the law in existence at that time”)). Here, we grant the government’s motion for summary affir- mance because its position is clearly right as a matter of law such that there can be no substantial question as to the outcome of the case. See Groendyke Transp., Inc., 406 F.2d at 1161–62. The govern- ment is clearly correct as a matter of law that our binding precedent in Rozier and Dubois II forecloses Williams’s Second Amendment challenge to § 922(g)(1). Williams’s attempt to disregard these precedents based on a purported conflict between them and Bondi is unavailing because Bondi did not involve a challenge to a felon disarmament statute, did not suggest that Rozier’s analysis of § 922(g)(1) was inconsistent with Bruen and Rahimi, and did not de- molish and eviscerate Rozier’s fundamental props. Accordingly, we grant the government’s motion for summary affirmance. USCA11 Case: 25-11358 Document: 25-1 Date Filed: 02/20/2026 Page: 10 of 10

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AFFIRMED.