Court of Appeals for the Sixth Circuit · 2025-07-09
18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
Role: applied; posture: 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; claim:
Uncertainty
None recorded
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 12
| Case | One applicable prohibited category | Section 925(a)(1) government-use firearm or ammunition exception | Actual or constructive possession | Firearm or ammunition under section 921 | Possession in or affecting commerce | Knowledge of possessing the firearm or ammunition |
|---|---|---|---|---|---|---|
| United States v. Jtton Edward Watson — 142 F.4th 872 (2025) · Court of Appeals for the Sixth Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 12
| Case | Knowledge of the relevant disqualifying status | Second Amendment limit on the unlawful-user theory applied to Hemani | Ship or transport in interstate or foreign commerce | Knowing shipping, transportation or receipt | Receipt of the prohibited object | Received object previously shipped or transported across borders |
|---|---|---|---|---|---|---|
| United States v. Jtton Edward Watson — 142 F.4th 872 (2025) · Court of Appeals for the Sixth Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| United States v. Jtton Edward Watson — 142 F.4th 872 (2025) · Court of Appeals for the Sixth Circuit · 2025 — satisfied · conceded (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Possession in or affecting commerce | satisfied Counted merits instance applied / merits basis: conceded; party: Jtton Edward Watson; count: 18 U.S.C. § 922(g)(1); subject: party=Jtton Edward Watson; count=18 U.S.C. § 922(g)(1) Commerce nexus established by the parties' stipulation that the firearm was manufactured in Brazil before the defendant possessed it in Ohio. | stipulated foreign manufacture (Brazil) of a pistol possessed in Ohio | 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.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [27630:27808] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.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).Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [32422:32626] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348. |
| United States v. Jtton Edward Watson — 142 F.4th 872 (2025) · Court of Appeals for the Sixth Circuit · 2025 — satisfied · conceded (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Knowledge of possessing the firearm or ammunition | satisfied Counted merits instance applied / merits basis: conceded; party: Jtton Edward Watson; count: 18 U.S.C. § 922(g)(1); subject: party=Jtton Edward Watson; count=18 U.S.C. § 922(g)(1) The element is established by stipulation, not by weighed evidence; the appellate ruling is that the stipulation waives the sufficiency challenge. The stipulation equally covered the prior conviction and knowledge of status (no separate blocks). | joint stipulation at a bench trial that the defendant knowingly possessed the pistol found in a lockbox in his car | 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.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [26750:27121] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.knowingly possessed a firearm and ammunition, that is, a 9mm Taurus, PTl11 Pro, bearing serial number TAP76805 (“firearm”) and ten rounds of 9mm ammunition.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [27473:27629] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.The officers also found a metal lockbox with a key in it that contained a loaded firearm.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [6201:6290] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.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.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [27877:28111] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.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.Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [26547:26734] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348. |
Court interpretations recorded from this case
interpretation
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.
United States v. Jtton Edward Watson — 142 F.4th 872 (2025) · Court of Appeals for the Sixth Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))
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.Source:
docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/872; Unicode character offsets [26750:27121] (end exclusive); SHA-256 753685ae1e41eb4d18dd06d7695bc1b07f5f6ed6ff39d30dfa0b2d87920de348.