Source: cases/18usc922/f4th-142-1270-us-v-edwards.case
Case source: https://www.neochart.com/catalog/cases/f4th/volume_142/1270/index.html
We have also rejected as-applied challenges to § 922(g), holding that the government demonstrates the required “minimal nexus” to interstate commerce when it proves that the firearms were manufactured outside the state where the offense took place and, thus, necessarily traveled in interstate commerce.
The government thus satisfied the minimal-nexus requirement here.
casedsl 1.2 # author: Flash3 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f4th/142/1270 name United States v. Shadon Edwards cite 142 F.4th 1270 (2025) court Court of Appeals for the Eleventh Circuit date 2025-06-27 url catalog/cases/f4th/volume_142/1270/index.html source ir/caselaw/f4th_142.jsonl sha1=0587e182dd7bb26303bce5b6ec28c7e68a2935b9 chars=44322 opinion op : panel by Newsom @620..44322 controlling party p1 : Shadon Edwards count c1 : 18 U.S.C. § 922(g)(1) law 18usc922 role applied posture criminal appeal after unconditional guilty plea to § 922(g)(1) with ACCA sentence; plea-voluntariness, Erlinger and Commerce Clause challenges all reviewed for plain error; affirmed result claimant-won element commerce-possession : satisfied [conceded] party p1 count c1 route prior-interstate-movement pattern firearm and ammunition possessed in Florida admitted (factual proffer) to have been manufactured out of state rule @42908..43211 | We have also rejected as-applied challenges to § 922(g), holding that the government demonstrates the required “minimal nexus” to interstate commerce when it proves that the firearms were manufactured outside the state where the offense took place and, thus, necessarily traveled in interstate commerce. fact @43491..43712 [supports] | Here, Edwards admitted in his factual proffer that the firearm and ammu- nition that he possessed in Florida were manufactured out of state and had therefore moved in interstate commerce prior to his pos- session of them. fact @2149..2295 [supports] | A search incident to Edwards’s arrest revealed that he had a Glock 43 nine-millimeter semi-automatic pistol, loaded with six rounds of ammunition. held @43713..43778 | The government thus satisfied the minimal-nexus requirement here. gloss The nexus is applied to this case's admitted facts in the course of rejecting a Commerce Clause challenge (facial and as-applied) that was not raised below. ? scope: the ruling answers a constitutional challenge on plain-error review, not a sufficiency challenge; kept as merits because the court states that the statutory minimal-nexus requirement was satisfied on the admitted facts