United States v. Johnathan Anton Williams

USCA11 Case: 23-13858 Document: 49-1 Date Filed: 08/11/2025 Page: 1 of 11

[DO NOT PUBLISH]

In the

United States Court of Appeals

For the Eleventh Circuit

____________________

No. 23-13858

Non-Argument Calendar

____________________

UNITED STATES OF AMERICA,

Plaintiff-Appellee,

versus

JOHNATHAN ANTON WILLIAMS,

Defendant-Appellant.

____________________

Appeal from the United States District Court

for the Middle District of Florida

D.C. Docket No. 8:22-cr-00308-JSM-AAS-1

____________________

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2 Opinion of the Court 23-13858

Before JORDAN, LUCK, and LAGOA, Circuit Judges.

PER CURIAM:

This case returns to us on remand from the Supreme Court.

Johnathan Williams appeals his conviction for possession of a fire-

arm and ammunition as a convicted felon, arguing that 18 U.S.C.

§ 922(g)(1) violates the Second Amendment and the Commerce

Clause, both facially and as applied to him. In our previous panel

opinion, we affirmed Williams’s conviction and sentence. Wil-

liams petitioned for a writ of certiorari, which the Supreme Court

granted in light of its decision in United States v. Rahimi, 602 U.S.

680 (2024). See Williams v. United States, 2025 WL 1603600 (U.S.

June 6, 2025) (Mem.). We now reconsider Willaims’ appeal with

the benefit of the Supreme Court’s guidance in Rahimi.

After careful review, we affirm Williams’s conviction. How-

ever, as both Williams and the government agree that the judg-

ment contains a clerical error incorrectly citing the offense of con-

viction as “18 U.S.C. §§ 922(g)(1) and (a)(2),” rather than 18 U.S.C.

§§ 922(g)(1) and 924(a)(8), we thus vacate Williams’s written judg-

ment, in part, and remand for the limited purpose of allowing the

district court to amend the judgment to reflect the proper statute.

I. FACTUAL AND PROCEDURAL HISTORY

Williams was indicted for possession of methamphetamine

with intent to distribute, in violation of 21 U.S.C. § 841(b)(1)(C)

(“Count One”); possession of a firearm in furtherance of a drug-

trafficking crime, in violation of 18 U.S.C. § 924(c)(1)(A)(i) (“Count

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23-13858 Opinion of the Court 3

Two”); and possession of a firearm and ammunition as a felon, in

violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) (“Count Three”).

Williams moved to dismiss Counts Two and Three of the

indictment, arguing that (1) both counts violated the Second

Amendment following New York State Rifle & Pistol Ass’n, Inc. v.

Bruen, 597 U.S. 1 (2022), and (2) Count Three violated the Com-

merce Clause. The government responded, asserting that this

Court’s precedent foreclosed both of Williams’s arguments. The

district court denied Williams’s motion to dismiss.

Williams waived his right to trial by jury and the case pro-

ceeded to a stipulated bench trial. Williams signed a factual proffer,

agreed that the facts were true, and the court accepted the stipula-

tions as evidence. The stipulated factual proffer included the fol-

lowing offense conduct. While conducting surveillance, law en-

forcement observed Williams give a man a tied-off plastic baggie in

exchange for U.S. currency from his car. After law enforcement

asked him to walk to the front of the car, a deputy observed, in

plain view, multiple empty sandwich bags and a digital scale

through the passenger window. When the officers asked Williams

to place his hands behind his back, he attempted to flee but was

apprehended. A search of the vehicle produced (1) a Taurus 9 mm

pistol with a magazine and one round in the chamber, found be-

tween the center console and the driver’s seat, (2) a Sig Saur pistol

magazine with 9 mm ammunition in the center console, (3) a .45

caliber round in the driver-side door compartment, (4) 27.73 grams

of methamphetamine, (5) two digital scales, and (6) $1,001.00 in

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4 Opinion of the Court 23-13858

U.S. currency. The gun was found near the narcotics and drug par-

aphernalia. Williams had the gun to “further and protect his drug

distribution.” An ATF agent determined that the gun was manu-

factured in Brazil, four rounds of Prvi Partisan ammunition were

manufactured in Serbia, and seven rounds of Armscor ammunition

were manufactured in the Philippines or Montana. Williams had

felony convictions for robbery, possession of cocaine, possession of

a controlled substance with intent to distribute, and being a felon

in possession of a firearm, and, on the day of the offense, Williams

knew that he was a felon. Williams had intended to distribute the

methamphetamine.

The district court found Williams guilty on all three counts

and sentenced Williams to a total of 104 months imprisonment,

followed by 36 months of supervised release. This appeal ensued.

II. STANDARD OF REVIEW

We review the constitutionality of a statute de novo as a ques-

tion of law. United States v. Wright, 607 F.3d 708, 715 (11th Cir.

2010). Section 922(g) of Title 18 of the United States Code prohibits

anyone who has been convicted of a crime punishable by more

than one year of imprisonment from possessing a firearm or am-

munition. 18 U.S.C. § 922(g)(1). We turn first to Williams’s argu-

ment that § 922(g) is unconstitutional under the Second Amend-

ment as applied to him and the Commerce Clause.1

1 The distinction between as applied and facial constitutional challenges “goes

to the breadth of the remedy employed by the Court, not what must be

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III. ANALYSIS

A. Second Amendment Challenge

In District of Columbia v. Heller, 554 U.S. 570 (2008), the Su-

preme Court first recognized that the Second Amendment protects

an individual’s right to possess and carry weapons for lawful self-

defense, unconnected with militia service. The Court then con-

cluded that “on the basis of both text and history,” D.C.’s law pro-

hibiting the possession of handguns in homes violated the Second

Amendment. Id. at 595. But the Heller Court also acknowledged

that the Second Amendment right to keep and bear arms was “not

unlimited,” emphasizing that “nothing in [its] opinion should be

taken to cast doubt on longstanding prohibitions on the possession

of firearms by felons.” Id. at 626. The Supreme Court labeled these

restrictions as “presumptively lawful.” Id. at 627 n.26. It specifi-

cally ruled that Heller only had a right to register his handgun and

carry it in his home if he was “not disqualified from the exercise of

Second Amendment rights.” Id. at 635.

After Heller, we considered and rejected, in United States v.

Rozier, 598 F.3d 768 (11th Cir. 2010) (per curiam), a constitutional

challenge to § 922(g)(1)’s prohibition on felons possessing firearms.

We explained in Rozier that “the first question to be asked” under

Heller “is whether one is qualified to possess a firearm.” Id. at 770.

When making this determination, a convicted felon’s Second

pleaded in a complaint.” Citizens United v. Fed. Election Comm’n, 558 U.S. 310,

331 (2010).

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Amendment right to bear arms “is not weighed in the same man-

ner as that of a law-abiding citizen.” Id. at 771. Instead, Heller rec-

ognized that prohibiting felons from possessing firearms was a

“presumptively lawful longstanding prohibition.” Id. (quotation

marks omitted). And this language from Heller “suggest[ed] that

statutes disqualifying felons from possessing a firearm under any

and all circumstances do not offend the Second Amendment.” Id.

We concluded that § 922(g)(1) was a “constitutional avenue to re-

strict the Second Amendment right of certain classes of people,”

including those with felony convictions. Id.

We rejected Rozier’s argument that the statement from Hel-

ler about “longstanding prohibitions on the possession of firearms

by felons” was “merely dicta” for two reasons. Id. at 771 n.6. First,

to the extent that the statement “limit[ed] the Court’s opinion to

possession of firearms by law-abiding and qualified individuals,” it

was necessary to the decision reached. Id. Second, even if the state-

ment were superfluous to Heller’s holding, we would still afford it

“considerable weight,” as dicta from the Supreme Court is not to

be lightly ignored. Id. Because Rozier, as a convicted felon, fell

within a class of people who could be excluded from firearm pos-

session, Rozier’s purpose for possessing a handgun and the fact that

he only used the gun in his home for purposes of self-defense were

“irrelevant.” Id. at 770.

Several years later, the Supreme Court in Bruen introduced

a new framework to correctly apply “Heller’s text-and-history

standard.” 597 U.S. at 39. At the first step, the court must decide

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whether the challenged law burdens conduct protected by the

plain text of the Second Amendment. Id. at 17, 32. If the law bur-

dens protected conduct, the government must demonstrate the re-

striction burdens the Second Amendment right in a way that is

“consistent with this Nation’s historical tradition of firearm regula-

tion.” Id. at 17.

Applying its historical test, the Court invalidated New

York’s licensing law, which required applicants to demonstrate a

“special need for self-defense” before obtaining a permit to carry

firearms in public. Id. at 38. Bruen relied on two main principles.

First, a total or near-total ban on carrying weapons outside the

home would infringe the Second Amendment right. Id. Second,

the state failed to identify a “historical tradition limiting public

carry only to those law-abiding citizens who demonstrate a special

need for self-defense.” Id. at 38–39.

Applying Bruen, we rejected a defendant’s Second Amend-

ment challenge to § 922(g)(1) in United States v. Dubois, 94 F.4th

1284, 1296 (11th Cir. 2024), cert. granted, judgment vacated sub nom.

Dubois v. United States, 145 S. Ct. 1041 (2025) (Mem.), reinstated by

139 F.4th 887 (11th Cir. 2025) (Dubois II). In Dubois II, we found the

challenge was foreclosed by Rozier, which “interpreted Heller as

limiting the [Second Amendment] right to ‘law-abiding and quali-

fied individuals’ and as clearly excluding felons from those catego-

ries by referring to felon-in-possession bans as presumptively law-

ful.” Id. at 1293 (quoting Rozier, 598 F.3d at 771 & n.6). We also

rejected the defendant’s argument that Bruen abrogated Rozier,

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8 Opinion of the Court 23-13858

observing that “Bruen, like Heller, repeatedly described the right as

extending only to ‘law-abiding, responsible citizens.’” Id. (quoting

Bruen, 597 U.S. at 26). Because Rozier stood as binding, it foreclosed

the defendant’s Second Amendment challenge to § 922(g)(1). Id.

Then, in Rahimi, the Supreme Court rejected a Second

Amendment challenge to 18 U.S.C. § 922(g)(8), which prohibits in-

dividuals subject to a domestic violence restraining order from pos-

sessing a firearm. 602 U.S. at 684–85, 693. The Court again de-

clared that prohibitions on “the possession of firearms by ‘felons

and the mentally ill,’ are ‘presumptively lawful.’” Id. at 699 (quot-

ing Heller, 554 U.S. at 626–27 & n.26).

The Court observed that in Heller and Bruen, it “used the

term ‘responsible’ to describe the class of ordinary citizens who un-

doubtedly enjoy the Second Amendment right.” Id. at 701–02.

Even in holding that the statute was not unconstitutional as ap-

plied, the Court rejected the government’s argument that a person

could be disarmed “simply because he is not ‘responsible.’” Id. at

701. It reasoned that the term was too vague to impose a mean-

ingful limitation. Id. But unlike individuals merely deemed irre-

sponsible, “[a]n individual found by a court to pose a credible threat

to the physical safety of another may be temporarily disarmed con-

sistent with the Second Amendment.” Id. at 702 (emphasis added).

In January 2025, the Supreme Court vacated our decision in

Dubois and remanded the case for further consideration after

Rahimi. See Dubois, 145 S. Ct. at 1041. We reinstated our previous

opinion in June 2025, concluding that “Rahimi—like [Bruen]—did

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not abrogate our holding in Rozier that section 922(g)(1) is consti-

tutional under the Second Amendment.” Dubois II, 139 F.4th at

889. We reasoned that “[t]he only time that the Rahimi majority

mentioned felons was to reiterate Heller’s conclusion that prohibi-

tions on the possession of firearms by felons and the mentally ill

are presumptively lawful.” Id. at 893 (internal quotation marks

omitted and alterations adopted). We stated in explicit terms that

“Rahimi reinforced—not undermined—Rozier.” Id. So, under both

Bruen and Rahimi, § 922(g) is constitutional as applied to Williams,

and the Second Amendment permits a permanent ban on his fire-

arm possession. We thus conclude that § 922(g) is constitutional as

applied to Williams.

B. Commerce Clause Challenge

We now turn to Williams’s challenge under the Commerce

Clause. The Commerce Clause reads: “The Congress shall have

Power . . . To regulate Commerce with foreign Nations, and

among the several States, and with the Indian Tribes.” U.S. CONST.

art. I, § 8, cl. 3. We have held that § 922(g) is constitutional under

the Commerce Clause. United States v. Stancil, 4 F.4th 1193, 1200

(11th Cir. 2021). We have also rejected as-applied challenges to 18

U.S.C. § 922(g), holding that the government proves a “minimal

nexus” to interstate commerce where it proves that the firearms

were manufactured outside the state where the offense took place

and thus necessarily traveled in interstate commerce. Wright, 607

F.3d at 715–16. In United States v. McAllister, we explicitly rejected

the argument that United States v. Lopez, 514 U.S. 549 (1995) ren-

dered § 922(g)(1) unconstitutional as applied to the appellant,

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holding that § 922(g)(1)’s statutory requirement of a connection to

interstate commerce could satisfy the “minimal nexus” require-

ment that remained in binding precedent. 77 F.3d 387, 390 (11th

Cir. 1996). Similarly, in United States v. Scott, we held that United

States v. Morrison, 529 U.S. 598 (2000) did not abrogate McAllister

because § 922(g)(1) contained an explicit statutory jurisdictional re-

quirement that “immunizes § 922(g)(1) from Scott’s facial constitu-

tional attack,” and Morrison did not compel a different conclusion

than reached in McAllister. 263 F.3d 1270, 1273 (11th Cir. 2001).

We thus conclude that Williams’s Commerce Clause challenge to

§ 922(g)(1) fails.

IV. CONCLUSION

For the reasons stated, we conclude that the district court

did not err in convicting Williams under § 922(g)(1) because his

challenges are foreclosed by Bruen, Rahimi, and our binding prece-

dent. See Rozier, 598 F.3d at 770–71; Dubois II, 139 F.4th at 893. Fur-

ther, as Williams conceded, his Commerce Clause arguments are

similarly foreclosed by our precedent. See McAllister, 77 F.3d at 390;

Scott, 263 F.3d at 1273. Accordingly, we affirm Williams’s convic-

tion under § 922(g)(1).

However, because the district court’s written judgment in-

correctly lists Williams’s offense as “18 U.S.C. §§ 922(g)(1) and

(a)(2),” rather than 18 U.S.C. §§ 922(g)(1) and 924(a)(8), we vacate

Williams’s written judgment, in part, and remand for the limited

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23-13858 Opinion of the Court 11

purpose of allowing the district court to amend the judgment to

reflect the proper statute. 2

AFFIRMED IN PART; VACATED IN PART AND

REMANDED WITH INSTRUCTIONS.

2 We may recognize errors in the judgment and remand with instructions for

the district court to correct the errors. See United States v. Anderton, 136 F.3d

747, 751 (11th Cir. 1998) (sua sponte remanding with directions to correct the

judgment, where it cited the wrong statute). Rule 36 allows a court “at any

time [to] correct a clerical error in a judgment, order, or other part of the rec-

ord, or correct an error in the record arising from oversight or omission.” Fed.

R. Crim. P. 36; United States v. Portillo, 363 F.3d 1161, 1164 (11th Cir. 2004).

Rule 36 encompasses “minor, uncontroversial errors” and may not be used to

correct substantive legal errors. Portillo, 363 F.3d at 1164–65. Because we con-

clude that the district court’s error below was purely clerical, Rule 36 author-

izes correction.