United States v. Shadon Edwards — 142 F.4th 1270 (2025) · Court of Appeals for the Eleventh Circuit · 2025

Court of Appeals for the Eleventh Circuit · 2025-06-27

18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)

Original case on neochart.com

Case and law context

18 U.S.C. § 922(g)

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; claim:

Uncertainty

Element commerce-possession: 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

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

18 U.S.C. § 922(g)
CaseOne applicable prohibited categorySection 925(a)(1) government-use firearm or ammunition exceptionActual or constructive possessionFirearm or ammunition under section 921Possession in or affecting commerceKnowledge of possessing the firearm or ammunition
United States v. Shadon Edwards — 142 F.4th 1270 (2025) · Court of Appeals for the Eleventh Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))· not addressed· not addressed· not addressed· not addressed· not addressed

Elements 7–12 of 12

18 U.S.C. § 922(g)
CaseKnowledge of the relevant disqualifying statusSecond Amendment limit on the unlawful-user theory applied to HemaniShip or transport in interstate or foreign commerceKnowing shipping, transportation or receiptReceipt of the prohibited objectReceived object previously shipped or transported across borders
United States v. Shadon Edwards — 142 F.4th 1270 (2025) · Court of Appeals for the Eleventh 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

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
United States v. Shadon Edwards — 142 F.4th 1270 (2025) · Court of Appeals for the Eleventh Circuit · 2025 — satisfied · conceded (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))Possession in or affecting commercesatisfied
Counted merits instance
applied / merits

basis: conceded; party: Shadon Edwards; count: 18 U.S.C. § 922(g)(1); subject: party=Shadon Edwards; count=18 U.S.C. § 922(g)(1)

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.
firearm and ammunition possessed in Florida admitted (factual proffer) to have been manufactured out of state
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.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1270; Unicode character offsets [42908:43211] (end exclusive); SHA-256 b8b80de26c39b50ccedb80ca27826928865da03a12ce33eb0778a95b6a7d60ea.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1270; Unicode character offsets [43491:43712] (end exclusive); SHA-256 b8b80de26c39b50ccedb80ca27826928865da03a12ce33eb0778a95b6a7d60ea.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1270; Unicode character offsets [2149:2295] (end exclusive); SHA-256 b8b80de26c39b50ccedb80ca27826928865da03a12ce33eb0778a95b6a7d60ea.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The government thus satisfied the minimal-nexus requirement here.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1270; Unicode character offsets [43713:43778] (end exclusive); SHA-256 b8b80de26c39b50ccedb80ca27826928865da03a12ce33eb0778a95b6a7d60ea.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations recorded from this case

interpretation

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.

United States v. Shadon Edwards — 142 F.4th 1270 (2025) · Court of Appeals for the Eleventh Circuit · 2025 (18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md))

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.
Source: docroot/ir/caselaw/f4th_142.jsonl#/f4th/142/1270; Unicode character offsets [42908:43211] (end exclusive); SHA-256 b8b80de26c39b50ccedb80ca27826928865da03a12ce33eb0778a95b6a7d60ea.