Petition for Writ of Certiorari — Ashley Moore, Petitioner v. United States

Supreme Court briefJan 8, 2026

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No. ______________

In the

Supreme Court of the United States

___________

Ashley Moore,

Petitioner,

v.

United States,

Respondent.

___________

On Petition for a Writ of Certiorari

to the Court of Appeals for the Fifth Circuit

___________

PETITION FOR A WRIT OF CERTIORARI

___________

Brandon E. Beck

GearyBeck, LLP

2301 Broadway

Lubbock, TX 79401

806-698-7050 (phone)

806-905-6564 (fax)

brandon@gearybeck.com

QUESTIONS PRESENTED

1.

Whether an individual’s probation or supervised release status

categorically strips them of Second Amendment protection under 18

U.S.C. § 922(g)(1), or whether courts must instead apply the BruenRahimi historical analysis to determine if the specific predicate offense

historically justified disarmament?

2.

Does 18 U.S.C. § 922(g)(1) violate the Commerce Clause when the

government’s only jurisdictional burden is to prove that a part of the

firearm crossed state lines at some point in the indeterminate past?

i

PARTIES TO THE PROCEEDING

Petitioner is Ashley Moore, who was the Defendant-Appellant in the court

below. Respondent, the United States, was the Plaintiff-Appellee in the court below.

No party is a corporation.

ii

RULE 14.1(b)(iii) STATEMENT

This case arises from the following proceedings in the United States Court of

Appeals for the Fifth Circuit and the Western District of Texas:

•

United States v. Moore, No. 25-50396, 2025 U.S. App. LEXIS 32720 (5th

Cir. Dec. 15, 2025)

•

United States v. Moore, No. 7:24-cr-218-2 (W.D. Tex. Feb. 13, 2025)

No other proceedings in state or federal trial or appellate courts, or in this

Court, are directly related to this case.

iii

TABLE OF CONTENTS

QUESTION PRESENTED.............................................................................................. i

PARTIES TO THE PROCEEDING ............................................................................... ii

TABLE OF AUTHORITIES............................................................................................v

PETITION FOR A WRIT OF CERTIORARI ................................................................ 1

OPINIONS BELOW ....................................................................................................... 1

JURISDICTION ............................................................................................................. 1

STATUTORY AND RULES PROVISIONS .................................................................. 1

STATEMENT OF THE CASE ....................................................................................... 3

REASONS FOR GRANTING THIS PETITION ........................................................... 5

I.

The Fifth Circuit erred in resolving Ms. Moore’s as-applied Second

Amendment challenge by relying on her supervision status rather than

conducting a Bruen-Rahimi historical analysis of her specific predicate

offense .................................................................................................................. 5

II.

18 U.S.C. § 922(g)(1), as interpreted by the Fifth Circuit, exceeds

Congress’s power under the Commerce Clause ............................................... 11

CONCLUSION ............................................................................................................. 15

APPENDICES

Opinion of the Fifth Circuit ............................................................................. App. A

Judgment of the Western District of Texas .................................................... App. B

iv

TABLE OF AUTHORITIES

Page(s)

Cases

Alderman v. United States,

131 S. Ct. 700 (2011) ................................................................................... 12, 13, 14

N.Y. State Rifle & Pistol Ass’n v. Bruen,

597 U.S. 1 (2022) ....................................................................... 3, 4, 5, 6, 7, 9, 10, 11

Scarborough v. United States,

431 U.S. 563 (1977) ............................................................................... 11, 12, 13, 14

United States v. Alderman,

565 F.3d 641 (9th Cir. 2009) ....................................................................... 12, 13, 14

United States v. Moore,

No. 25-50396, 2025 U.S. App. LEXIS 32720 (5th Cir. Dec. 15, 2025) ............ 1, 5, 6

United States v. Dorris,

236 F.3d 582 (10th Cir. 2000) ................................................................................. 14

United States v. Gateward,

84 F.3d 670 (3d Cir. 1996) ...................................................................................... 13

United States v. Giglio,

126 F.4th 1039 (5th Cir. 2025) ..................................................................... 6, 7, 8, 9

United States v. Hanna,

55 F.3d 1456 (9th Cir. 1995) ................................................................................... 14

United States v. Kirk,

105 F.3d 997 (5th Cir. 1997) (en banc) ................................................................. 13

United States v. Kuban,

94 F.3d 971 (5th Cir. 1996) .................................................................................... 13

United States v. Lemons,

302 F.3d 769 (7th Cir. 2002) ................................................................................... 13

United States v. Lopez,

514 U.S. 549 (1995) ............................................................................... 11, 12, 13, 14

v

United States v. Patton,

451 F.3d 615 (10th Cir. 2006) ................................................................................. 13

United States v. Rahimi,

602 U.S. 680 (2024) ................................................................... 3, 4, 5, 6, 7, 9, 10, 11

United States v. Rawls,

85 F.3d 240 (5th Cir. 1996) ..................................................................................... 13

United States v. Santiago,

238 F.3d 213 (2d Cir. 2001) .................................................................................... 13

United States v. Seekins,

52 F.4th 988 (5th Cir. 2022) ................................................................................... 14

United States v. Shelton,

66 F.3d 991 (8th Cir. 1995) ............................................................................... 13, 14

United States v. Smith,

101 F.3d 202 (1st Cir. 1996) ................................................................................... 13

United States v. Wright,

607 F.3d 708 (11th Cir. 2010) ................................................................................. 14

Williams v. Illinois,

399 U.S. 235 (1970) ............................................................................................. 5, 10

Statutes

18 U.S.C. § 1201(a) (repealed 1986) ............................................................................ 11

18 U.S.C. § 922(g)(1)............................................................... 2, 3, 5, 6, 8, 10, 11, 13, 14

18 U.S.C. § 922(q)(1)(A)................................................................................................ 12

28 U.S.C. § 1254(1) ......................................................................................................... 1

Act of Apr. 5, 1790, ch. 1516, § 1, 13 Statutes at Large of Pennsylvania

(James T. Mitchell & Henry Flanders eds., 1908) .............................................. 7, 8

Act of Oct. 28, 1786, 1 Laws of the Commonwealth of Massachusetts, at 346

(J.T. Buckingham ed., 1807) ................................................................................. 8, 9

vi

U.S. Const. amend II .................................................................................. 1, 3, 4, 5, 6, 7

U.S. Const. art. 1 § 8 .......................................................................... 1, 2, 11, 12, 13, 14

vii

PETITION FOR A WRIT OF CERTIORARI

Petitioner Ashley Moore seeks a writ of certiorari to review the judgment of

the United States Court of Appeals for the Fifth Circuit.

OPINIONS BELOW

The opinion of the Court of Appeals is reported at United States v. Moore, No.

25-50396, 2025 U.S. App. LEXIS 32720 (5th Cir. Dec. 15, 2025). The district court did

not issue a written opinion.

JURISDICTION

The Fifth Circuit entered judgment on December 15, 2025. This Court has

jurisdiction pursuant to 28 U.S.C. § 1254(1).

RULES AND GUIDELINES PROVISIONS

This Petition involves the Second Amendment:

A well regulated Militia, being necessary to the security of

a free State, the right of the people to keep and bear Arms,

shall not be infringed.

U.S. Const. amend II.

This Petition also involves the Commerce Clause:

Congress shall have Power … To regulate Commerce with

foreign Nations, and among the several States, and with

the Indian Tribes.

U.S. Const. art. 1 § 8.

Finally, this Petition involves the federal felon-in-possession statute:

It shall be unlawful for any person … who has been

convicted in any court of, a crime punishable by

imprisonment for a term exceeding one year … to …

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possess in or affecting commerce, any firearm or

ammunition[.]

18 U.S.C. § 922(g)(1).

2

STATEMENT OF THE CASE

This Petition arises from a direct appeal from a direct appeal raising an asapplied constitutional challenge and Commerce Clause challenge to a conviction

under 18 U.S.C. § 922(g)(1).

On November 7, 2024, an officer and a CPS worker conducted a welfare check

in an RV occupied by Ashley Moore, Appellant. While conducting the welfare check,

the officer observed a round of ammunition and a firearm magazine in plain view.

The officer then obtained a search warrant for the RV, which led to the discovery of

a firearm. A criminal history check revealed that Ms. Moore had a prior felony

conviction for aiding and abetting drug trafficking.

The government charged Ms. Moore with one count of felon in possession of a

firearm, in violation of 18 U.S.C. § 922(g)(1). On January 7, 2025, Ms. Moore filed a

written motion to dismiss the indictment, in which she alleged: (1) 18 U.S.C.

§ 922(g)(1) is unconstitutional, on its face, under the Second Amendment; (2) 18

U.S.C. § 922(g)(1) is unconstitutional, as applied to Ms. Moore, under the Second

Amendment; and (3) 18 U.S.C. § 922(g)(1) is unconstitutional because it exceeds

Congress’s power under the Commerce Clause. The government opposed dismissal in

a written response. The district court denied Ms. Moore’s motion to dismiss.

On January 27, 2025, Ms. Moore pleaded guilty. She did so without a plea

agreement. On May 8, 2025, the district court sentenced Ms. Moore to 37 months

imprisonment for the instant offense, followed by a three-year term of supervised

release. Ms. Moore was on supervised release at the time she committed the offense.

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On appeal, the Fifth Circuit affirmed Ms. Moore’s conviction by granting the

government’s motion for summary affirmance. Rather than resolving the Second

Amendment challenge under the Bruen-Rahimi framework, it instead affirmed on

the basis that she was on supervised release at the time she possessed the firearm.

On the Commerce Clause issue, it affirmed under longstanding Fifth Circuit

precedent.

This Petition advances the issues raised in the motion to dismiss and re-urged

on appeal, under both the Second Amendment and the Commerce Clause.

4

REASONS FOR GRANTING THIS PETITION

I.

The Fifth Circuit erred in resolving Ms. Moore’s as-applied Second

Amendment challenge by relying on her supervision status rather

than conducting a Bruen-Rahimi historical analysis of her specific

predicate offense.

The Fifth Circuit below declined to analyze the challenged statute on its own

terms. Instead of conducting the rigorous historical analysis that the Bruen-Rahimi

test requires for Ms. Moore’s specific predicate offense—aiding and abetting drug

distribution—the court affirmed under extratextual categorical exception based

solely on Ms. Moore’s supervision status. In other words, the court held that Ms.

Moore is foreclosed on her as-applied challenge to 18 U.S.C. § 922(g)(1), even if she

would otherwise prevail, simply because she was on supervised release at the time of

her instant offense. United States v. Moore, No. 25-50396, 2025 U.S. App. LEXIS

32720, at *1 (5th Cir. Dec. 15, 2025) (citing United States v. Giglio, 126 F.4th 1039,

1044 (5th Cir. 2025)).

This approach violates established principles dating back to Williams v.

Illinois, which forbid courts from defending a statute by pointing to entirely different

grounds for regulation that are not embodied in the challenged law itself. 399 U.S.

235, 238-39 (1970). Section 922(g)(1) prohibits firearm possession based on prior

felony conviction, not current supervision status, yet the Fifth Circuit sidestepped the

central question by concluding that Ms. Moore could theoretically be disarmed for an

unrelated reason.

Second, the decision below highlights the fundamental constitutional infirmity

of Section 922(g)(1)’s categorical lifetime ban on all felons. The government cannot

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meet its burden under Bruen and Rahimi to demonstrate historical tradition

supporting such a sweeping prohibition because no such tradition exists—neither the

federal government nor any state categorically disarmed all felons until the 20th

century, nearly two centuries after the Second Amendment’s ratification. The circuit

split on these issues has left millions of Americans with inconsistent constitutional

protections depending solely on their geographic location. This case presents both

questions cleanly: her non-violent felony offense exemplifies a conviction that

historically would not have justified permanent disarmament, while the court’s

reliance on her supervision status rather than the challenged statute itself illustrates

the methodological error plaguing post-Bruen jurisprudence.

A.

The Fifth Circuit sidestepped the required historical analysis

by creating an extratextual “supervision exception” to the

Second Amendment.

The decision below represents a fundamental departure from established

constitutional methodology. Rather than conducting the rigorous historical analysis

that Bruen and Rahimi require for the specific predicate offense that triggered Ms.

Moore’s § 922(g)(1) prohibition—aiding and abetting drug distribution—the panel

relied a categorical exception based solely on her supervision status. Moore, 2025 U.S.

App. LEXIS 32720, at *1 (affirming under United States v. Giglio, 126 F.4th 1039,

1044 (5th Cir. 2025)). This approach contradicts both this Court’s precedents and

Bruen-Rahimi’s historical methodology.

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1.

The Fifth Circuit in Giglio improperly bypassed BruenRahimi’s

requirements

through

interest-balancing

disguised as categorical rules.

The Fifth Circuit’s reliance on United States v. Giglio, 126 F.4th 1039 (5th Cir.

2025)

exemplifies

the

methodological

error

that

has

infected

post-Bruen

jurisprudence. Giglio purported to conduct an historical analysis but actually

engaged in the exact type of interest-balancing that Bruen forbids, reasoning that the

government’s interest in monitoring and controlling individuals under community

supervision justifies restricting their Second Amendment rights. 126 F.4th at 1045.

Giglio’s analysis fails at every level. The court concluded that “Early American

history reveals that individuals could be disarmed while carrying out such sentences”

and that this tradition justified disarming individuals on supervised release. Id. at

1045. But this sweeping assertion lacks the specific historical analysis that BruenRahimi demands. As this Court has emphasized, “[w]hy and how the regulation

burdens the right are central to this inquiry.” United States v. Rahimi, 602 U.S. 680,

692 (2024). The government must demonstrate not just that some historical

disarmament occurred, but that it occurred for reasons analogous to the specific

modern prohibition at issue.

2.

Giglio’s historical analysis relies on inapposite foundingera forfeiture laws.

Giglio’s historical foundation falters under scrutiny. The court relied primarily

on founding-era forfeiture laws, particularly Pennsylvania’s 1790 statute that

required individuals convicted of “robbery, burglary, sodomy or buggery” to “forfeit to

the commonwealth all … goods and chattels” and “be sentenced to undergo a

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servitude of any term … not exceeding ten years.” Act of Apr. 5, 1790, ch. 1516, § 1,

13 Statutes at Large of Pennsylvania, at 511–12 (James T. Mitchell & Henry

Flanders eds., 1908).

These forfeiture laws are fundamentally different from § 922(g)(1) in both their

“why” and “how”—the very factors Rahimi identified as central to the constitutional

inquiry. 602 U.S. at 692.

The “Why” Problem: The forfeiture laws targeted specific violent crimes that

directly threatened public safety. The 1790 Pennsylvania law applied only to robbery,

burglary, and sodomy—serious violent offenses. Similarly, the Massachusetts law

cited in Giglio applied to “anti-riot laws” involving persons who “unlawfully,

routously, riotously and tumultuously continue together” to prevent government

officers from fulfilling their duties. Act of Oct. 28, 1786, 1 Laws of the Commonwealth

of Massachusetts, at 346, 347 (J.T. Buckingham ed., 1807). These laws responded to

immediate public safety threats, not the broad category of all felonies that § 922(g)(1)

encompasses.

The “How” Problem: The forfeiture laws imposed fundamentally different

burdens than modern community supervision. Historical sentences typically involved

physical custody or banishment from the community entirely. For example, the

Pennsylvania law imposed “servitude” not probation or supervision. Act of Apr. 5,

1790, ch. 1516, § 1, 13 Statutes at Large of Pennsylvania, at 511, 511–12 (James T.

Mitchell & Henry Flanders eds., 1908). The Massachusetts law imposed

8

“imprisonment” not probation or supervision. Act of Oct. 28, 1786, 1 Laws of the

Commonwealth of Massachusetts, at 346, 347 (J.T. Buckingham ed., 1807).

Modern community supervision operates entirely differently. Individuals on

probation or supervised release live freely in their communities, work regular jobs,

support families, and exercise most constitutional rights while subject to limited

conditions. The founding-era concept of disarming someone physically confined or

banished bears little resemblance to disarming someone who otherwise lives as a free

member of the community.

This difference in “how” the burden operates is constitutionally significant.

When the historical precedent involved complete state control over an individual’s

movements and circumstances, disarmament was merely one aspect of total

deprivation of liberty. But when someone lives freely in the community—where the

need for self-defense is greatest—the burden of disarmament is qualitatively

different and more severe than anything the historical precedent contemplated.

Ultimately, Giglio creates an arbitrary system where defendants with identical

predicate offenses face different constitutional protections based solely on whether

they are under supervision. Such a result undermines the value-neutral historical

analysis that Bruen-Rahimi requires.

B.

The approach below violates basic principles of constitutional

adjudication.

The Fifth Circuit’s methodology violates fundamental principles governing

constitutional challenges to criminal statutes. Courts cannot uphold a conviction

9

under one law by pointing to entirely different grounds for regulation that are not

embodied in the challenged statute.

1.

Williams v. Illinois prohibits defending statutes based on

alternative regulatory approaches.

This Court’s decision in Williams v. Illinois directly condemns the approach

taken below. 399 U.S. 235 (1970). In Williams, the state argued that its statute was

“not constitutionally infirm simply because the legislature could have achieved the

same result by some other means.” Id. at 238-39. This Court rejected that argument,

explaining that the state’s authority to use alternative regulatory approaches “does

not resolve the [constitutional] issue” actually presented by the challenged law. Id. at

239. The Court then reached the merits of the constitutional challenge to the statute.

Ms. Moore’s probation status is precisely the kind of alternative means

constitutional avoidance that Williams rejected. Section 922(g)(1) prohibits

possession based on prior felony conviction, not current supervision status. The

statute’s text makes this clear: it applies to one “who has been convicted in any court

of, a crime punishable by imprisonment for a term exceeding one year.” 18 U.S.C.

§ 922(g)(1). Current supervision status is irrelevant to this conviction-based

prohibition.

2.

The supervision approach reintroduces the interestbalancing that Bruen rejected.

Bruen explicitly rejected means-ends scrutiny in favor of a historical analysis

specifically to avoid an “interest-balancing inquiry” that requires deciding on “a caseby-case basis whether the right is really worth insisting upon.” N.Y. State Rifle &

10

Pistol Ass’n v. Bruen, 597 U.S. 1, 22-23 (2022) (emphasis in original). The supervision

exception recreates exactly this prohibited analysis by requiring courts to assess

whether governmental monitoring interests justify restricting Second Amendment

rights.

As Justice Kavanaugh emphasized in Rahimi, this represents “a value-laden

and political task that is usually reserved for the political branches.” 602 U.S. at 73233 (Kavanaugh, J., concurring). When courts abandon analysis of the challenged

regulation’s historical foundations and instead evaluate collateral circumstances,

they engage in precisely the “value-laden” judgments about constitutional worthiness

that Bruen sought to eliminate.

II.

18 U.S.C. § 922(g)(1), as interpreted by the Fifth Circuit, exceeds

Congress’s power under the Commerce Clause.

18 U.S.C. § 922(g)(1) should require proof of more than interstate activity at

the time a firearm was manufactured—perhaps either recent movement in interstate

commerce or some commercial conduct on a defendant’s part. In the absence of such

a connection to interstate commerce, the statute exceeds Congress’s power under the

Commerce Clause.

In Scarborough v. United States, this Court held, as a matter of statutory

interpretation, that the government could satisfy the interstate commerce element of

Section 922(g)’s predecessor, 18 U.S.C. § 1201(a) (repealed 1986), by proving that the

firearm had traveled across state lines at any prior point, even if the defendant’s

possession occurred all in one state. See 431 U.S. 563, 577 (1977). Eighteen years

later, in United States v. Lopez, 514 U.S. 549 (1995), the Court struck down a statute

11

that made it a federal crime “for any individual knowingly to possess a firearm at a

place that the individual knows, or has reasonable cause to believe, is a school zone,”

18 U.S.C. § 922(q)(1)(A), reasoning that the law violated the Commerce Clause

because it “neither regulate[d] a commercial activity nor contain[ed] a requirement

that the possession be connected in any way to interstate commerce.” 514 U.S. at 551.

Lopez clarified that, for a law that regulates neither the channels nor the

instrumentalities of commerce to nevertheless comport with the Commerce Clause,

the regulated activity must “substantially affect” interstate commerce. Id. at 559.

Section 922(q) failed that test because there was no evidence that the intrastate, noncommercial act of possessing a gun in close proximity to a school had the requisite

“substantial” impact on interstate economic activity, and the statute “contain[ed] no

jurisdictional element which would ensure, through case-by-case inquiry, that the

firearm possession in question affect[ed] interstate commerce.” Id. at 561.

In the following years, numerous jurists have identified and called upon this

Court to resolve the apparent tension between Lopez and Scarborough. Justice

Thomas, for instance, has observed that “Scarborough, as the lower courts have read

it, cannot be reconciled with Lopez because it reduces the constitutional analysis to

the mere identification of a jurisdictional hook” that, like § 922(g)’s jurisdictional

element, “seems to permit Congress to regulate or ban possession of any item that

has ever been offered for sale or crossed state lines.” Alderman v. United States, 131

S. Ct. 700, 702-03 (2011) (Thomas, J., joined by Scalia, J., dissenting from the denial

of certiorari). That result, Justice Thomas explained, is not only inconsistent with the

12

Lopez framework but “could very well remove any limit on the commerce power” if

taken to its logical extension. Id. at 703.

Despite similarly perceiving Scarborough as in fundamental and irreconcilable

conflict with Lopez, the prevailing view of the courts of appeals is that Scarborough

implicitly assumed the constitutionality of § 922(g)’s predecessor statute, and that

“[a]ny doctrinal inconsistency between Scarborough and [this] Court’s more recent

decisions is not for [the lower courts] to remedy.” United States v. Alderman, 565 F.3d

641, 645 (9th Cir. 2009); United States v. Patton, 451 F.3d 615, 636 (10th Cir. 2006);

United States v. Kuban, 94 F.3d 971, 977 (5th Cir. 1996) (DeMoss, J., dissenting); see

also United States v. Kirk, 105 F.3d 997, 1015 n.25 (5th Cir. 1997) (en banc) (Jones,

J., for half of the equally divided court) (“not[ing] the tension between” Scarborough

and Lopez but observing that the Fifth Circuit has felt constrained to nevertheless

“continue to enforce § 922(g)(1)” because a court of appeals is “not at liberty to

question the Supreme Court’s approval of [Section 922(g)’s] predecessor statute”).

The courts of appeals have therefore made clear their intention to follow

Scarborough “until the Supreme Court tells [them] otherwise.” Patton, 451 F.3d at

648. And nine of those courts have specifically upheld the constitutionality of

§ 922(g)(1) based on Scarborough’s minimal-nexus test. See United States v. Smith,

101 F.3d 202, 215 (1st Cir. 1996); United States v. Santiago, 238 F.3d 213, 216-17 (2d

Cir. 2001); United States v. Gateward, 84 F.3d 670, 671-72 (3d Cir. 1996); United

States v. Rawls, 85 F.3d 240, 242-43 (5th Cir. 1996); United States v. Lemons, 302

F.3d 769, 771-72 (7th Cir. 2002); United States v. Shelton, 66 F.3d 991, 992 (8th Cir.

13

1995); United States v. Hanna, 55 F.3d 1456, 1461-62, 1462 n.2 (9th Cir. 1995); United

States v. Dorris, 236 F.3d 582, 584-86 (10th Cir. 2000); United States v. Wright, 607

F.3d 708, 715-16 (11th Cir. 2010).

This question is important and independently warrants review. Section

922(g)(1) is one of the most often-applied federal criminal statutes. Yet, as Justice

Thomas has observed, and as many lower-court judges have echoed, the degree of

proof needed to convict under that statute is in serious tension with the Court’s

modern understanding of the limited nature and scope of the federal power to

regulate noneconomic, intrastate activity. In recently urging the Fifth Circuit to

reconsider this issue en banc, Judge Ho emphasized that the “constitutional limits on

governmental power do not enforce themselves.” United States v. Seekins, 52 F.4th

988, 989 (5th Cir. 2022) (Ho, J., dissenting from the denial of rehearing en banc). The

interpretation of § 922(g)(1)’s jurisdictional element that the circuits understand

Scarborough to require effectively “allows the federal government to regulate any

item so long as it was manufactured out-of-state—without any regard to when, why,

or by whom the item was transported across state lines.” Id. at 990. That broad

conception of federal regulatory authority is at odds with the Lopez framework. Only

this Court can “prevent [that framework] from being undermined by a 1977 precedent

that d[id] not squarely address the constitutional issue.” Alderman, 131 S. Ct. at 703

(Thomas, J., dissenting from the denial of certiorari).

14

CONCLUSION

Petitioner respectfully requests that this Court grant certiorari to review the

judgment of the United States Court of Appeals for the Fifth Circuit.

Respectfully submitted,

/s/ Brandon E. Beck

GearyBeck, LLP

2301 Broadway

Lubbock, TX 79401

806-698-7050 (phone)

806-905-6564 (fax)

brandon@gearybeck.com

Attorney for Petitioner

15

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