Court of Appeals for the Eleventh Circuit · 2025-06-27
18usc922: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
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
| 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. 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
| 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. 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
| Case | Element | Holding and scope | Pattern | Exact 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 commerce | satisfied 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.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.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.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. |
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.