United States v. Ronald Norvale Williams

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 11, 2025
Docket24-1244
StatusUnpublished

This text of United States v. Ronald Norvale Williams (United States v. Ronald Norvale Williams) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Ronald Norvale Williams, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0199n.06

No. 24-1244 FILED UNITED STATES COURT OF APPEALS Apr 11, 2025 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE v. ) UNITED STATES DISTRICT ) COURT FOR THE EASTERN RONALD NORVALE WILLIAMS, ) DISTRICT OF MICHIGAN Defendant-Appellee. ) ) OPINION )

Before: SUHRHEINRICH, MOORE, and NALBANDIAN, Circuit Judges.

KAREN NELSON MOORE, Circuit Judge. In 1987, then eighteen-year-old Ronald

Norvale Williams, Defendant-Appellee, was convicted of first- and second-degree murder.

Although initially sentenced to life without parole, Williams was resentenced to a term of years

and released on parole. After his release, and despite his status as a felon and parolee, Williams

allegedly possessed a stolen pistol in violation of 18 U.S.C. § 922(g)(1). Applying the Supreme

Court’s decision in Bruen, the district court held that § 922(g)(1) was unconstitutional as applied

to Williams and therefore dismissed his indictment. We disagree with the district court.

For the reasons that follow, we REVERSE the district court’s order dismissing the

indictment and REMAND for proceedings consistent with this opinion.

I. BACKGROUND

On April 4, 2023, the Government filed a one-count indictment charging Williams with

violation of § 922(g)(1). United States v. Williams, 718 F. Supp. 3d 651, 654 (E.D. Mich. 2024). No. 24-1244, United States v. Williams

In 1987, Williams was convicted of first- and second-degree murder. Id. at 655 n.2. After his

sentence was converted from life without parole to a term of years, Williams was released

on parole. Id. As a condition on his parole, Williams was prohibited from possessing a firearm.

Id. at 662 n.16. Despite this condition and his status as a felon, the Government’s indictment

alleges that “[o]n or about March 2, 2023, . . . the defendant, Ronald Williams, knowing that he

had been convicted of a crime punishable by imprisonment for a term exceeding one year,

knowingly possessed, in and affecting interstate commerce, a firearm . . . in violation of Title 18,

United States Code, Section 922(g)(1).” Id. at 654 (alteration in original) (quoting R. 1 (Indictment

at 1) (Page ID #1)).

Williams pleaded not guilty to the charge, id., and, on June 15, 2023, filed a motion to

dismiss the indictment, id. at 655. Williams argued that § 922(g)(1) is unconstitutional in light

of New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). Williams, 718 F. Supp.

3d at 655. Following briefing, the district court granted Williams’s motion to dismiss the

indictment. Id. at 655, 683. “Because the government d[id] not identify a historical analog that

[wa]s ‘distinctly similar’ or ‘relevantly similar’ to § 922(g)(1), the Court [wa]s required by Bruen

to find the statute unconstitutional as applied to [Williams].” Id. at 683. The district court did not

consider whether Williams, because of his prior murder convictions and parolee status, is

dangerous and therefore can be lawfully disarmed pursuant to § 922(g)(1).

The Government appealed this decision. R. 34 (Notice of Appeal) (Page ID #516).

II. STANDARD OF REVIEW

We review de novo the district court’s order. See United States v. Goins, 118 F.4th 794,

797 (6th Cir. 2024).

2 No. 24-1244, United States v. Williams

III. DISCUSSION

Williams argues on appeal that § 922(g)(1) is facially unconstitutional and unconstitutional

as applied to him. Both arguments are foreclosed by binding precedent. See United States

v. Williams, 113 F.4th 637, 662–63 (6th Cir. 2024); Goins, 118 F.4th at 804–05. Accordingly, we

reverse the district court’s order dismissing Williams’s indictment.1

A. Facial Challenge

Williams’s argument that § 922(g)(1) is facially unconstitutional is foreclosed by our

precedent. Williams, 113 F.4th at 657. We are bound by this decision. See Salmi v. Sec’y of

Health & Hum. Servs., 774 F.2d 685, 689 (6th Cir. 1985).

Williams tries to evade this insurmountable obstacle by arguing that the dangerousness

inquiry described in Williams, 113 F.4th at 657–61, renders § 922(g)(1) overbroad and void for

vagueness, Appellee Br. at 26–33. Although some judges have criticized Williams along the lines

suggested by Williams, see Range v. Att’y Gen. U.S., 124 F.4th 218, 281–85 (3d Cir. 2024)

(en banc) (Krause, J., concurring in the judgment), we are in no position to second-guess binding

precedent. Williams definitively concluded that § 922(g)(1) “is constitutional on its face.”

113 F.4th at 662. Furthermore, it is not clear that an overbroad judicial interpretation can render

the underlying statute unconstitutional under the void-for-vagueness doctrine. See Columbia Nat.

Res., Inc. v. Tatum, 58 F.3d 1101, 1106 (6th Cir. 1995); see also Wills v. Pszczolkowski, 125 F.4th

534, 539 (4th Cir. 2025); United States v. Jennings, --- F. Supp. 3d ---, 2024 WL 4560602, at *6

(E.D. Mich. 2024).

1 We note that the district court did not have the benefit of either Williams or Goins when it entered its order.

3 No. 24-1244, United States v. Williams

B. As-Applied Challenge

We reverse the district court’s decision on the as-applied challenge, and hold that

§ 922(g)(1) is constitutional as applied to Williams. Williams’s two murder convictions and

parolee status support our holding.

As this court explained in Williams, § 922(g)(1) is constitutional when it is “applied to

dangerous people.” 113 F.4th at 662–63. Thus, a defendant must be afforded “an opportunity

to make an individualized showing that he himself is not actually dangerous.” Id. at 663. In

assessing dangerousness, someone who has committed “a crime ‘against the body of another

human being,’” like murder, “will have a very difficult time, to say the least, of showing he is not

dangerous.” Id. The finding must involve “fact-specific dangerousness determinations after

taking account of the unique circumstances of the individual, including details of his specific

conviction.” Id. In making these determinations, courts “may consider a defendant’s entire

criminal record.” Id. at 659–60, 663.

Although the district court did not conduct an individualized dangerousness analysis, we

hold that there is sufficient evidence in the record demonstrating that Williams could be disarmed

under § 922(g)(1). Murder is exactly the type of prior felony conviction that Williams

contemplates as rendering an individual dangerous under § 922(g)(1). See id. at 662 (attempted

murder); accord United States v. Parham, 119 F.4th 488, 496 (6th Cir. 2024) (same). Williams

responds to his inescapable past by pointing to his exemplary disciplinary record while in prison

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Related

United States v. Erick Williams
113 F.4th 637 (Sixth Circuit, 2024)
United States v. Christopher Goins
118 F.4th 794 (Sixth Circuit, 2024)
United States v. Tarrence Parham
119 F.4th 488 (Sixth Circuit, 2024)
Bryan Range v. Attorney General United States
124 F.4th 218 (Third Circuit, 2024)

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