United States v. Jtton Edward Watson

142 F.4th 872 (2025) Court of Appeals for the Sixth Circuit 2025-07-09

criminal appeal after bench-trial conviction under § 922(g)(1) on stipulated facts (entered to expedite appeal of a suppression ruling); suppression ruling affirmed; sufficiency challenge held waived by the stipulation; affirmed (result: claimant-won)

Facts

  1. 4 Possession in or affecting commerce satisfied conceded
    The firearm was shipped and transported in interstate and foreign commerce before JTTONALI ONE EYE EL BEY (“Jtton Watson”) possessed it as the firearm was manufactured in Brazil.
  2. 4 Possession in or affecting commerce satisfied conceded
    Under these circumstances, the district court committed no error—much less clear error—in accepting Watson’s stipulation to all four elements of felony possession of a firearm under 18 U.S.C. § 922(g)(1).
  3. 5 Knowledge of possessing the firearm or ammunition satisfied conceded
    The officers also found a metal lockbox with a key in it that contained a loaded firearm.
  4. 5 Knowledge of possessing the firearm or ammunition satisfied conceded
    Watson’s factual stipulation to all essential elements of his felon-in-possession charge constitutes a waiver of his right to challenge the sufficiency of the evidence for his conviction.
  5. 5 Knowledge of possessing the firearm or ammunition satisfied conceded
    To prove guilt under § 922(g)(1), the government was otherwise required prove beyond a reasonable doubt that: (i) the defendant had a prior felony conviction, (ii) the defendant knew that he had a prior felony conviction, (iii) the defendant thereafter knowingly possessed the firearm specified in the indictment, and (iv) the firearm had traveled in interstate commerce.
  6. 5 Knowledge of possessing the firearm or ammunition satisfied conceded
    knowingly possessed a firearm and ammunition, that is, a 9mm Taurus, PTl11 Pro, bearing serial number TAP76805 (“firearm”) and ten rounds of 9mm ammunition.
  7. 5 Knowledge of possessing the firearm or ammunition satisfied conceded
    It is further stipulated and agreed that this Stipulation may be introduced into evidence as an exhibit, and that the facts herein stipulated have the same status, dignity, and effect as the undisputed testimony of credible witnesses.