United States v. Samuels

CourtCourt of Appeals for the Tenth Circuit
DecidedMarch 27, 2025
Docket24-6018
StatusUnpublished

This text of United States v. Samuels (United States v. Samuels) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth 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. Samuels, (10th Cir. 2025).

Opinion

Appellate Case: 24-6018 Document: 59-1 Date Filed: 03/27/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT March 27, 2025 _________________________________ Christopher M. Wolpert Clerk of Court UNITED STATES OF AMERICA,

Plaintiff - Appellee, No. 24-6018 v. (D.C. No. 5:18-CR-00152-PRW-1) (W.D. Okla.) LAWRENCE SAMUELS, JR.,

Defendant - Appellant. _________________________________

ORDER AND JUDGMENT* _________________________________

Before HARTZ, KELLY, and ROSSMAN, Circuit Judges.** _________________________________

Defendant-Appellant, Lawrence Samuels, Jr., appeals from the district court’s

revocation of his supervised release based on his violation of a condition which

prohibited him from possessing a firearm. I R. 69. Mr. Samuels argues that this

condition is unconstitutional under the Second Amendment and thus could not serve as a

basis for the district court’s revocation of his supervised release. Aplt. Br. at 7. He also

argues that the district court erred in re-imposing this allegedly unconstitutional condition

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. ** After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. Appellate Case: 24-6018 Document: 59-1 Date Filed: 03/27/2025 Page: 2

for his additional term of supervised release. Id. at 7–8. Exercising jurisdiction under

28 U.S.C. § 1291, we affirm.

Background

In 2004, Mr. Samuels pled guilty to possession with intent to distribute a

controlled substance, 21 U.S.C. §§ 841(a)(1) & (b)(1)(B)(iii). II R. 4; Aplt. Br. at 1.

The district court sentenced him to 210 months’ incarceration and five years’ supervised

release. II R. 4. After his sentence was commuted by President Obama, Mr. Samuels

began his term of supervised release in May 2018. I R. 53. His term was set to expire in

May 2023. Id. Critical to this appeal, one of the conditions of Mr. Samuels’s supervised

release was that he must not possess a firearm, destructive device, or other dangerous

weapon. Id. at 69.

In September 2022, while on supervised release, Mr. Samuels was pulled over for

speeding while driving a rental car in Texas. Id. at 54. Mr. Samuels consented to the

officer’s search of the car, and the officer found a handgun hidden in a sock in the engine

bay. Id. Mr. Samuels was arrested for being a felon in possession of a firearm. Id.

Shortly thereafter, his probation officer filed a Petition for Warrant or Summons for

Offender Under Supervision, alleging that Mr. Samuels violated both (1) the mandatory

condition of his release to not commit another federal, state, or local crime; and (2) the

standard condition to not possess a firearm.1 Id.

1 The petition also alleged that Mr. Samuels left the judicial district without permission of the district court or his probation officer. I R. 54. Mr. Samuels admitted this violation at the revocation hearing, and it is not at issue in this appeal. See id.; Aplt. Br. at 4. 2 Appellate Case: 24-6018 Document: 59-1 Date Filed: 03/27/2025 Page: 3

At the revocation hearing, Mr. Samuels disputed the violations arising from his

possession of a firearm. Id. at 55. In deciding whether Mr. Samuels had constructive

possession of the firearm in the engine bay, the district court applied a “sole-occupancy”

standard and found Mr. Samuels guilty of the alleged violations. Id. The district court

revoked Mr. Samuels’s supervised release and sentenced him to 24 months’ imprisonment

and 36 months’ supervised release. Id. at 13–17. The district court imposed the same

condition prohibiting Mr. Samuels from possessing a firearm. Id. at 17.

Mr. Samuels appealed, and this court reversed and remanded on the basis that the

district court applied the wrong standard for determining constructive possession of the

firearm. Id. at 52–66; United States v. Samuels, No. 23-6000, 2023 WL 8596457, at *1

(10th Cir. Dec. 12, 2023). Specifically, this court held that the district court should have

applied a “joint-occupancy” standard because the vehicle was a rental car, Mr. Samuels

had possession of the car for only three days, and the firearm was located in the engine

bay rather than the passenger compartment. Samuels, 2023 WL 8596457, at *4–5. On

remand, the district court heard argument on Mr. Samuels’s constructive possession of the

firearm under the correct joint-occupancy standard. III R. 4–40. Applying that standard,

the district court again determined that Mr. Samuels had constructive possession of the

firearm and therefore violated the conditions of his supervised release.2 Id. at 27–30.

The district court imposed a sentence of time served followed by two years’ supervised

2 Mr. Samuels does not challenge the district court’s constructive possession analysis in this appeal. See generally Aplt. Br.

3 Appellate Case: 24-6018 Document: 59-1 Date Filed: 03/27/2025 Page: 4

release. Id. at 38. The term of supervised release included the same conditions that were

previously imposed, including the condition prohibiting Mr. Samuels from possessing a

firearm, which is at issue in this appeal. Id. at 38–39.

Discussion

Because Mr. Samuels did not object to the imposition of this condition of

supervised release below, our review is for plain error. United States v. Mike, 632 F.3d

686, 691 (10th Cir. 2011). “To establish plain error, the defendant must show: (1) error,

(2) that is plain, which (3) affects substantial rights, and which (4) seriously affects the

fairness, integrity, or public reputation of judicial proceedings.” Id. at 691–92 (quotations

omitted). “Legal questions relating to the revocation of supervised release are reviewed

de novo.” United States v. Williams, 106 F.4th 1040, 1044 (10th Cir. 2024) (quotations

omitted).

Mr. Samuels asks this court to immediately terminate his supervised release

because the condition of supervised release prohibiting him from possessing a firearm is

unconstitutional under the Second Amendment. Aplt. Br. at 8. More specifically, he

argues that the district court (1) erred in revoking his supervised release based on this

condition, and (2) could not re-impose this condition as a condition of additional

supervised release. Id. at 7–9. Both arguments turn on whether restrictions on felons

possessing firearms violate the Second Amendment. See id.; Aplee. Br. at 5. Indeed, the

condition of supervised release prohibiting Mr. Samuels from possessing a firearm must

comport with the Second Amendment. See Mike, 632 F.3d at 692.

Mr. Samuels’s arguments are foreclosed by this court’s precedent. In Vincent v.

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