Eleventh Circuit Re-Affirms § 922(g)(1) after Bruen/Rahimi and Clarifies “In-Connection-With” Enhancement under § 2K2.1(b)(6)(B)
– Commentary on United States v. Thomas Youngblood, No. 24-10053 (11th Cir. 2025)

1. Introduction

Case Overview. In United States v. Thomas Jamel Youngblood, the Eleventh Circuit confronted two increasingly common questions that have arisen in federal firearms litigation since the Supreme Court’s watershed Second Amendment decision in N.Y. State Rifle & Pistol Ass’n v. Bruen (2022) and its follow-up in United States v. Rahimi (2024):

  • Is the felon-in-possession statute, 18 U.S.C. § 922(g)(1), still constitutional?
  • How should district courts apply the four-level “in connection with another felony offense” enhancement found in U.S.S.G. § 2K2.1(b)(6)(B) after the en banc decision in United States v. Dupree, which cautioned against blind deference to the Sentencing Guidelines’ commentary?

Parties. The United States prosecuted Thomas Jamel Youngblood, a six-time convicted robber, for possessing a stolen pistol obtained during the burglary of an apartment. After a guilty plea, he received a 108-month prison sentence, already reduced from the statutory maximum via a government § 5K1.1 substantial-assistance motion.

Issues on Appeal.

  1. A Second Amendment as-applied challenge to § 922(g)(1) in light of Bruen and Rahimi.
  2. Whether the district court reversibly erred by using the Guidelines’ commentary to impose the § 2K2.1(b)(6)(B) enhancement.

2. Summary of the Judgment

The Eleventh Circuit (Judges Jordan, Branch, and Anderson, per curiam) affirmed both the conviction and the 108-month sentence:

  • Constitutionality of § 922(g)(1). The panel held that existing circuit precedent—United States v. Rozier (2010) as reaffirmed by United States v. Dubois (2025)—remains binding and forecloses any Second Amendment attack on the felon-in-possession ban. Neither Bruen nor Rahimi disturbed those precedents.
  • Guidelines Enhancement. The district court (1) treated § 2K2.1(b)(6)(B) as unambiguous; (2) found that Youngblood possessed the firearm “in connection with” the burglary in which he found it; and (3) therefore applied the four-level increase. Because that conclusion followed directly from the guideline’s text—and not from disputed commentary—no error (plain or otherwise) occurred.

3. Analysis

3.1 Precedents Cited

The decision rests on a lattice of Supreme Court and Eleventh Circuit authority:

  • N.Y. State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022).
    Introduced the two-step “text-and-history” test for all firearm regulations, discarding tiers of scrutiny.
  • United States v. Rahimi, 602 U.S. 680 (2024).
    Upheld § 922(g)(8) (domestic-violence restraining order dispossession) under Bruen, emphasizing historical analogues for disarming “dangerous” individuals.
  • United States v. Rozier, 598 F.3d 768 (11th Cir. 2010).
    The Circuit’s leading decision sustaining § 922(g)(1) against a general Second Amendment challenge.
  • United States v. Dubois, 2025 WL 1553843 (11th Cir. 2025).
    Held that Bruen and Rahimi did not overrule Rozier; continues to bind panels absent an intervening Supreme Court decision “clearly on point.”
  • United States v. Dupree, 57 F.4th 1269 (11th Cir. 2023) (en banc).
    Announced that guideline commentary is not controlling when the text is unambiguous, citing Kisor v. Wilkie.
  • United States v. James, 135 F.4th 1329 (11th Cir. 2025).
    Declared § 2K2.1(b)(6)(B) unambiguous; commentary unnecessary.
  • United States v. Brooks, 112 F.4th 937 (11th Cir. 2024).
    Held that possessing a firearm acquired during another felony satisfies § 2K2.1(b)(6)(B).
  • Plain-error framework cases: Wright (2010), Ramirez-Flores (2014), Verdeza (2023), Horn (2025).

3.2 Legal Reasoning

  1. Second Amendment Claim.
    • Because Youngblood never raised the claim below, plain-error review applied. Under step one of that test, an error cannot be “plain” if existing precedent directly forecloses the argument.
    • Both Rozier and the panel’s recent Dubois decision squarely upheld § 922(g)(1). Without a supervening Supreme Court case condemning the statute, the panel was bound to reject the challenge.
  2. Guideline Enhancement.
    • Youngblood conceded (on appeal) that § 2K2.1(b)(6)(B)’s text is clear; his sole complaint was that the district court “relied on commentary.” The record showed otherwise: the sentencing judge rested on the guideline’s words, not Note 14.
    • Under Brooks, possessing a gun that is the fruit of a burglary still constitutes possession “in connection with” that burglary because the weapon could facilitate escape or embolden the offender. Therefore, the enhancement applied squarely on the merits, mooting any Dupree issue.

3.3 Likely Impact of the Decision

Second Amendment Jurisprudence.

  • The Eleventh Circuit signals that, until the Supreme Court invalidates § 922(g)(1) explicitly, district courts and panels must continue to apply it. This stabilizes dozens of felon-in-possession prosecutions currently pending in the circuit.
  • The opinion emphasizes stare decisis, limiting the immediate ripple effects of Bruen and Rahimi and discouraging defendants from raising new as-applied theories absent novel Supreme Court guidance.

Sentencing Practice.

  • The Court clarifies that Dupree does not bar judges from applying unambiguous guideline provisions—only from using commentary to expand them. Where the rule fits a defendant’s conduct on its face, no supplementary commentary is needed.
  • By endorsing a broad construction of “in connection with,” the panel preserves a potent upward adjustment tool in firearm cases, even when the gun is merely discovered during a burglary rather than used to commit it.

4. Complex Concepts Simplified

As-Applied Challenge
Argues a statute is unconstitutional only as applied to the challenger’s specific facts, unlike a facial challenge that attacks all applications of the law.
Plain-Error Review
A four-prong appellate standard applicable when an issue was not raised below: (1) error, (2) that is plain, (3) affecting substantial rights, and (4) seriously affecting the fairness or integrity of the proceedings.
U.S.S.G. § 2K2.1(b)(6)(B)
A Sentencing Guidelines provision adding four offense levels when a defendant “used or possessed any firearm or ammunition in connection with another felony offense.”
Guideline Commentary vs. Text
The commentary historically explains or interprets guideline text. After Kisor and the Eleventh Circuit’s Dupree, courts must first decide whether the text is ambiguous; if not, commentary loses binding force.
§ 5K1.1 Motion
Government request for a downward departure based on the defendant’s “substantial assistance” in investigating or prosecuting others.

5. Conclusion

United States v. Youngblood may not rewrite constitutional doctrine, but it performs two consequential functions:

  1. It freezes the status quo on the felon-in-possession statute within the Eleventh Circuit, refusing to extrapolate Bruen or Rahimi into a categorical right for convicted felons to bear arms.
  2. It reinforces a pragmatic reading of § 2K2.1(b)(6)(B), confirming that courts can (and should) rely on the provision’s plain language without defaulting to guideline commentary, thereby harmonizing Dupree, James, and Brooks.

Going forward, defense counsel in the Eleventh Circuit face an uphill climb when challenging § 922(g)(1) or the “in connection with” enhancement absent a Supreme Court directive expressly undercutting existing circuit precedent. Meanwhile, sentencing judges gain added confidence that applying § 2K2.1(b)(6)(B) based on the guideline’s clear text will survive appellate scrutiny even in a post-Dupree landscape.