1. Whether the adverse judgment of a state court denying a federal statutory claim on the merits sup- plies Article III injury sufficient for review under 28 U.S.C. §1257(a), or whether—as ASARCO’s dictum would have it, and contrary to the historical under- standing and practice underlying this Court’s appel- late review of state-court judgments—this Court’s Ju- risdiction over state-court constructions of federal law runs 1n one direction only: reviewable when a state court vindicates a federal right, but not when it denies one.

2. Whether a debt collector violates 15 U.S.C. §1692c(b) by transmitting a consumer’s personal fi- nancial information to a third-party vendor for use in preparing, analyzing and mailing a collection letter, including whether that transmission constitutes a communication “in connection with the collection of any debt.”

Since the Court issued its ruling in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022), frontline defense lawyers and prosecutors, along with district courts and courts of appeals, have grappled with how the holding applies to § 922(¢)(1). Is the statute facially invalid? Is 1t subject to as-applied challenge? If so, how does that challenge work? Criminal defense lawyers and prosecutors have spent hours upon hours litigating these issues. District courts and appellate courts have expended massive amounts of time and energy ruling on these issues. Defense lawyers cannot stop raising the issue because this Court has not given us any final answers. Without answers from this Court, defense lawyers cannot tell clients that challenging the constitutionality of § 922(g)(1) is frivolous, even if the applicable court of appeals has rejected the argument. So, we must keep filing motions. We are stuck in purgatory, or ground hog day, or whatever metaphor strikes your fancy.

Perhaps the Court needed to flesh out Bruen on lesser used subsections of § 922(¢g) before tackling subsection (g)(1). United States v. Rahimi, 602 U.S. 680 (2024) (§ 922(¢)(8)); United States v. Hemani, 1468. Ct. 1677 (2026) (§ 922(g)(3)). That’s understandable. But the time has come. We need an answer on § 922(g)(1) and we need it now.

The Question Presented 1s:

Whether 18 U.S.C. § 922(g)(1), the federal statute that prohibits

anyone who has been convicted of “a crime punishable by imprisonment

for a term exceeding one year’ from possessing a firearm, violates the

Second Amendment as applied to Petitioner, based solely on prior

violent offenses?

Since the Court issued its ruling in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022), frontline defense lawyers and prosecutors, along with district courts and courts of appeals, have grappled with how the holding applies to § 922(¢)(1). Is the statute facially invalid? Is 1t subject to as-applied challenge? If so, how does that challenge work? Criminal defense lawyers and prosecutors have spent hours upon hours litigating these issues. District courts and appellate courts have expended massive amounts of time and energy ruling on these issues. Defense lawyers cannot stop raising the issue because this Court has not given us any final answers. Without answers from this Court, defense lawyers cannot tell clients that challenging the constitutionality of § 922(g)(1) is frivolous, even if the applicable court of appeals has rejected the argument. So, we must keep filing motions. We are stuck in purgatory, or ground hog day, or whatever metaphor strikes your fancy.

Perhaps the Court needed to flesh out Bruen on lesser used subsections of § 922(¢g) before tackling subsection (g)(1). United States v. Rahimi, 602 U.S. 680 (2024) (§ 922(¢)(8)); United States v. Hemani, 1468. Ct. 1677 (2026) (§ 922(g)(3)). That’s understandable. But the time has come. We need an answer on § 922(g)(1) and we need it now.

The Question Presented 1s:

Whether 18 U.S.C. § 922(g)(1), the federal statute that prohibits

anyone who has been convicted of “a crime punishable by imprisonment

for a term exceeding one year’ from possessing a firearm, violates the

Second Amendment as applied to Petitioner, based solely on prior

violent offenses?

1

1. Should this Court grant, vacate, and remand for reconsideration because of an intervening circuit decision that may invalidate precedent on which the panel opinion below relies?

2. Does Petitioner’s 18 U.S.C. § 922(¢g)(1) conviction violate the Second Amendment?

3. May Congress criminalize intrastate firearm possession based solely on the fact that the firearm crossed state lines at some point before the defendant possessed it?

1