Bondi Does Not Abrogate Rozier: Eleventh Circuit Reaffirms § 922(g)(1) Second Amendment Challenges Are Foreclosed Absent Clear Supreme Court Instruction

Case: United States v. Mario Martinez Williams (11th Cir. Feb. 20, 2026) (per curiam, non-argument calendar; not for publication)
Statute: 18 U.S.C. § 922(g)(1) (felon in possession)
Disposition: Summary affirmance

1. Introduction

Mario Martinez Williams appealed his federal conviction for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment in the district court, arguing the statute was unconstitutional under the Second Amendment as applied to him in light of New York State Rifle & Pistol Ass'n, Inc. v. Bruen and United States v. Rahimi.

On appeal, Williams also attempted to reframe the governing circuit law: he asserted that United States v. Dubois (Dubois II), which reaffirmed the constitutionality of § 922(g)(1) based on United States v. Rozier, was inconsistent with the Eleventh Circuit’s en banc decision in NRA v. Bondi. He contended that under the prior-panel-precedent rule, Bondi should control and require application of the Bruen/Rahimi historical-tradition framework to his § 922(g)(1) as-applied challenge.

The government moved for summary affirmance, arguing Williams’s appeal was foreclosed as a matter of binding precedent.

2. Summary of the Opinion

The Eleventh Circuit summarily affirmed. Applying the summary-disposition standard from Groendyke Transp., Inc. v. Davis, the court held that the government was “clearly right as a matter of law” because Williams’s Second Amendment challenge to § 922(g)(1) is foreclosed by binding Eleventh Circuit precedent: United States v. Rozier and United States v. Dubois (Dubois II).

The panel rejected Williams’s claim that NRA v. Bondi undermined or displaced those decisions. Bondi addressed a different kind of firearm regulation (Florida’s restrictions on firearm purchases by minors), did not discuss § 922(g)(1) or Dubois I, and did not “demolish and eviscerate” the reasoning that supports Rozier. Therefore, under the prior-panel-precedent rule, the panel was bound to follow Rozier and Dubois II.

3. Analysis

3.1. Precedents Cited (and how they drove the result)

• Groendyke Transp., Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969)
  Role in this case: Provided the procedural vehicle—summary affirmance—when “the position of one of the parties is clearly right as a matter of law” or the appeal is frivolous. The panel used this standard to avoid full merits briefing/argument because existing precedent made the outcome inevitable.
• Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en banc)
  Role in this case: Explained why old Fifth Circuit decisions (including Groendyke) remain binding in the Eleventh Circuit.
• United States v. Gruezo, 66 F.4th 1284 (11th Cir. 2023)
  Role in this case: Stated the general standard of review: constitutional challenges are reviewed de novo.
• District of Columbia v. Heller, 554 U.S. 570 (2008)
  Role in this case: The foundational Supreme Court decision recognizing an individual Second Amendment right, while simultaneously stating that “nothing in this opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons.” That “presumptively lawful” language is a key prop supporting Eleventh Circuit precedent upholding § 922(g)(1).
• United States v. Rozier, 598 F.3d 768 (11th Cir. 2010)
  Role in this case: The controlling circuit precedent. Rozier held that § 922(g)(1) does not violate the Second Amendment, even for firearms possessed “purely for self-defense,” treating felon disarmament as a “presumptively lawful longstanding prohibition” under Heller. The Williams panel treated Rozier as binding unless abrogated.
• New York State Rifle & Pistol Ass'n, Inc. v. Bruen, 597 U.S. 1 (2022)
  Role in this case: Williams invoked Bruen to argue that the Second Amendment analysis must be “text and history,” not means-end scrutiny. The panel, however, did not reach a fresh Bruen analysis because prior panel precedent (Rozier, as reaffirmed in Dubois II) controlled.
• United States v. Rahimi, 602 U.S. 680 (2024)
  Role in this case: Williams argued Rahimi supported his as-applied challenge. The opinion treated Rahimi as consistent with, not destructive of, the continued reliance on Heller’s “presumptively lawful” language and the historical acceptability of disarming certain categories of people.
• United States v. Dubois (Dubois I), 94 F.4th 1284 (11th Cir. 2024), vacated, 145 S. Ct. 1041 (2025) (mem.), reinstated, Dubois II, 139 F.4th 887 (11th Cir. 2025)
  Role in this case: Dubois II is the Eleventh Circuit’s post-Rahimi reaffirmation that Rozier remains binding and that Rahimi did not abrogate it. The Williams panel relied on Dubois II to reject the argument that Bruen/Rahimi reopened § 922(g)(1) in this circuit.
• NRA v. Bondi, 133 F.4th 1108 (11th Cir. 2025) (en banc)
  Role in this case: Williams’s attempted “off-ramp” from Rozier/Dubois II. He argued Bondi was inconsistent with Dubois II and required a Bruen/Rahimi merits analysis. The panel held Bondi did not address felon disarmament, did not discuss § 922(g)(1), and did not abrogate Rozier.
• Florida Commissioner of Agriculture v. Attorney General, 148 F.4th 1307 (11th Cir. 2025)
  Role in this case: Contextual support that the Eleventh Circuit applies the Bruen framework in appropriate cases, but it did not displace the categorical treatment of felons. Notably, the opinion emphasized the continued historical tradition of disarming felons and suggested the government could later show other groups are “relevantly similar to felons.”
• United States v. Archer, 531 F.3d 1347 (11th Cir. 2008); United States v. Gillis, 938 F.3d 1181 (11th Cir. 2019); United States v. Lightsey, 120 F.4th 851 (11th Cir. 2024)
  Role in this case: These decisions supply the governing articulation of the prior-panel-precedent rule and the strict “abrogation” standard: later Supreme Court/en banc decisions must be “clearly on point” and must “actually abrogate or directly conflict,” not merely weaken earlier precedent. Lightsey adds the vivid formulation that abrogation requires “demolish[ing] and eviscerat[ing]” fundamental props.
• United States v. Jackson, 55 F.4th 846 (11th Cir. 2022); United States v. Golden, 854 F.3d 1256 (11th Cir. 2017); Smith v. GTE Corp., 236 F.3d 1292 (11th Cir. 2001)
  Role in this case: Reinforced that panels cannot evade binding precedent by claiming an “overlooked reason” or analytical defect; even arguably wrong precedent remains binding until properly overruled.

3.2. Legal Reasoning (why the court reached this result)

The opinion is best understood as a decision about precedent and hierarchy rather than a fresh application of Bruen’s two-step historical test. The panel’s reasoning proceeded in three moves:

1. Procedural gateway: summary affirmance is appropriate under Groendyke Transp., Inc. v. Davis.
   Because the Eleventh Circuit already had binding precedent squarely rejecting Second Amendment challenges to § 922(g)(1), there was “no substantial question” about the outcome. That made full appellate process unnecessary.
2. Substantive control: United States v. Rozier and United States v. Dubois (Dubois II) foreclose Williams’s claim.
   The panel treated Rozier as the foundational circuit holding that felons, “as a class,” may be excluded from firearm possession consistent with the Second Amendment. Dubois II then revalidated that binding effect after the Supreme Court’s Rahimi decision, concluding that Rahimi did not abrogate Rozier. Thus, Williams’s as-applied challenge could not be entertained on the merits by a three-judge panel.
3. No abrogation via NRA v. Bondi.
   Williams argued that Bondi (en banc) required the panel to apply Bruen/Rahimi directly to § 922(g)(1). But under the prior-panel-precedent framework (United States v. Archer; United States v. Gillis; United States v. Lightsey), Bondi could only free the panel from Rozier if it was “clearly on point” and directly conflicted with (or “demolished and eviscerated”) Rozier’s supporting premises. The panel found it did not: Bondi concerned minors’ purchase restrictions, did not address felon disarmament, and said nothing that negated Rozier’s reliance on Heller’s “presumptively lawful” observation.

The bottom line is an institutional one: even if Bruen and Rahimi have reshaped Second Amendment doctrine, Eleventh Circuit panels treat § 922(g)(1) as already resolved by binding circuit precedent unless the Supreme Court speaks with greater specificity about felon disarmament.

3.3. Impact

• Immediate effect in the Eleventh Circuit: Defendants convicted under § 922(g)(1) will continue to face a near-categorical bar to Second Amendment challenges at the panel level, including as-applied challenges, because Rozier and Dubois II are treated as controlling.
• Doctrinal effect: The opinion reinforces a strict view of “abrogation” and confirms that broad en banc Second Amendment reasoning in a different context (like minors in Bondi) will not be read to silently unsettle felon-disarmament precedent.
• Litigation strategy effect: The viable pathways to change are (a) Supreme Court review that is “clearly on point” to § 922(g)(1), or (b) Eleventh Circuit en banc reconsideration of Rozier. Merely invoking Bruen/Rahimi or pointing to doctrinal tension is unlikely to succeed under the circuit’s prior-panel-precedent doctrine.
• National context: Although this opinion is “not for publication,” it illustrates how some circuits are managing post-Bruen uncertainty: by treating earlier felon-disarmament rulings as intact unless Supreme Court precedent directly addresses and repudiates them.

4. Complex Concepts Simplified

• As-applied vs. facial challenges: An “as-applied” challenge argues a law is unconstitutional in the challenger’s particular circumstances; a “facial” challenge argues the law is unconstitutional in all (or most) applications. Williams brought an as-applied challenge to § 922(g)(1).
• Bruen’s “text and history” test: If the Second Amendment’s text covers the conduct, the government must show the regulation fits within the Nation’s historical tradition of firearm regulation. Here, the panel did not newly apply this test because it considered § 922(g)(1) controlled by existing circuit precedent.
• “Presumptively lawful” regulations: In District of Columbia v. Heller (and reiterated in United States v. Rahimi), the Court indicated felon-in-possession prohibitions are “presumptively lawful.” Eleventh Circuit precedent uses this to treat felon disarmament as constitutionally permissible in principle.
• Prior-panel-precedent rule: A three-judge panel must follow earlier panel decisions unless the Supreme Court or the Eleventh Circuit sitting en banc clearly overrules them. The panel emphasized that later cases must be “clearly on point” and directly conflicting—not just in tension.
• Summary affirmance: A streamlined appellate disposition used when the outcome is legally obvious under controlling precedent, as described in Groendyke Transp., Inc. v. Davis.

5. Conclusion

United States v. Mario Martinez Williams is a precedent-management decision: the Eleventh Circuit held that § 922(g)(1) Second Amendment challenges remain foreclosed by United States v. Rozier and United States v. Dubois (Dubois II), and that NRA v. Bondi does not abrogate those cases because it did not address felon disarmament or directly conflict with their rationale. The opinion underscores the court’s strict application of the prior-panel-precedent rule and signals that, in this circuit, meaningful change to § 922(g)(1)’s Second Amendment status must come from an on-point Supreme Court decision or en banc reconsideration.