Dangerousness Without Remand: United States v. Meeks
Sixth Circuit further refines the Williams “actual dangerousness” test and endorses robust use of the homicide cross-reference at sentencing

I. Introduction

United States v. Ricky Jaimal Meeks, No. 23-2074 (6th Cir. July 24 2025), is the Sixth Circuit’s latest encounter with two fast-developing doctrinal fronts:

• The aftermath of New York State Rifle & Pistol Ass’n v. Bruen (2022) and the Circuit’s own landmark decision in United States v. Williams (2024) on the continued constitutionality of 18 U.S.C. § 922(g)(1).
• The proper use of the Sentencing Guidelines’ homicide cross-reference, U.S.S.G. § 2K2.1(c)(1)(B), when a felon-in-possession is believed to have killed someone with the charged firearm.

Meeks, a felon, was convicted under § 922(g)(1) after police found a Taurus 9 mm handgun in his vehicle during a domestic-violence call. Ballistic testing later linked that same weapon to an unsolved murder committed a year earlier. At sentencing the district court, applying the cross-reference to second-degree murder, maxed out Meeks’s sentence at 180 months. On appeal, Meeks:

1. Mounted an as-applied Second Amendment challenge to § 922(g)(1); and
2. Argued that the sentencing court clearly erred in finding he had murdered the victim.

The Sixth Circuit affirmed on both fronts, generating a decision that—though “Not Recommended for Publication”—nonetheless sharpens several doctrinal tools and is already being cited in subsequent district-court briefing.

II. Summary of the Judgment

Chief Judge Sutton and Judge Stranch joined Judge Ritz’s opinion, which holds:

1. § 922(g)(1) survives Meeks’s as-applied challenge. Under Williams, a felon may rebut the statutory firearm ban only by making an “individualized showing” that he is not actually dangerous. Meeks’s extensive criminal history—particularly a prior assault with a dangerous weapon—unequivocally established dangerousness, obviating any need to remand for fact-finding.
2. The district court properly applied the Guidelines cross-reference to second-degree murder. Ballistic, video, and circumstantial evidence plausibly tied Meeks to the 2021 homicide; the sentencing finding was therefore not clearly erroneous.

Result: conviction and 180-month sentence affirmed.

III. Analysis

A. Precedents Cited and Their Influence

• United States v. Williams, 113 F.4th 637 (6th Cir. 2024)
  – Established the “three-tier” framework for assessing individual dangerousness in § 922(g)(1) challenges. Meeks cements the principle that violent crimes against the person are practically dispositive evidence of dangerousness.
• United States v. Morton, 123 F.4th 492 (6th Cir. 2024)
  – Articulated de novo review for statutory-constitutionality questions; cited for review standard.
• United States v. Henson, No. 24-3494, 2025 WL 1009666 (6th Cir. Apr. 3 2025)
  – Declined remand where record “indisputably” showed dangerousness; Meeks expands this no-remand posture.
• United States v. Caston, 851 F. App’x 557 (6th Cir. 2021) and United States v. Mills, 126 F.4th 470 (6th Cir. 2025)
  – Elaborated the deferential “plausibility” test for clear-error review of sentencing fact-findings.
• United States v. Curtis, 2025 WL 448945 (6th Cir. Feb. 10 2025)
  – Earlier endorsed cross-reference to first-degree murder; Meeks follows and underscores the Circuit trend.

B. The Court’s Legal Reasoning

1. Second Amendment Challenge

Under Williams, the Sixth Circuit retained the felony-possession bar for “dangerous” individuals. Meeks did not seriously contest dangerousness; instead he argued that the trial court never evaluated it. The panel reasoned:

• The appellate record already contained ample proof—prior convictions for assault with a dangerous weapon, drug trafficking, and high-speed flight.
• Remand is unnecessary when dangerousness is “indisputable”; efficiency and judicial economy justify affirmance without further hearing (Henson).
• The court emphasized that crimes against the person (category 1 in Williams) may by themselves justify permanent disarmament.

2. Sentencing Cross-Reference

The district court increased Meeks’s offense level from 26 to 38 by finding he committed second-degree murder. On review, the panel applied “clear-error” scrutiny:

• Ballistics: Unique W9MM2020 casings linked the Taurus pistol to the homicide. The rarity of the ammunition sharpened the inference.
• Vehicle & Video Evidence: Surveillance showed a light-colored Chevy Equinox with a “sunset” Michigan plate before and after the shooting; Meeks routinely drove that very vehicle.
• Temporal Proximity: Cell-site data placed Meeks 1.5 hours before and 0.5 hours after the shooting near the scene. The panel called the overlapping timestamps “particularly important.”
• Circumstantial Mosaic: The court adopted a “too many coincidences” rationale. On clear-error review, alternative inferences (e.g., another shooter) did not create a “definite and firm conviction” of mistake.

C. Likely Impact of the Decision

1. More streamlined handling of § 922(g)(1) challenges.
   – Meeks signals that, post-Williams, defendants must bring concrete evidence of non-dangerousness or face summary affirmance. District courts can now rely on the “no-remand” principle where records are clear.
2. Encouragement of aggressive homicide cross-references.
   – The Sixth Circuit continues to bless sentencing courts’ use of circumstantial evidence. Expect prosecutors to present thorough ballistics and vehicle-tracking evidence even in mere possession cases.
3. Clarification on review standards.
   – The opinion reiterates that constitutional arguments are de novo, sentencing fact-findings clear-error, and that facial/as-applied distinctions matter for forfeiture analysis.
4. Potential influence outside the Circuit.
   – Other circuits wrestling with post-Bruen challenges may look to Meeks’s endorsement of the “dangerousness” gateway as a pragmatic limiting principle.

IV. Complex Concepts Simplified

• As-Applied vs. Facial Challenge: A facial challenge says a statute is invalid in all applications; an as-applied challenge says it is unconstitutional for this person given his circumstances.
• Dangerousness Inquiry: Under Williams, courts examine a defendant’s entire record to see if he poses a threat. Violent felonies virtually guarantee a finding of dangerousness.
• Sentencing Guidelines Cross-Reference: U.S.S.G. § 2K2.1(c)(1)(B) tells judges to switch to the homicide guideline when the firearm resulted in death, if it yields a higher offense level.
• Standard of Review:
  • De novo – appellate court decides anew with no deference.
  • Plain error – heightened hurdle when issue not preserved.
  • Clear error – deferential; appellate court overturns only if firmly convinced the lower court erred.
• Preponderance of the Evidence: More likely than not (51%); standard applied at sentencing—not “beyond a reasonable doubt.”
• Ballistic Matching: Forensic method comparing unique marks left on shell casings by a firearm’s breech face and firing pin; here, linked Meeks’s pistol to the 2021 murder.

V. Conclusion

United States v. Meeks fortifies the Sixth Circuit’s post-Bruen jurisprudence in two respects. First, it makes clear that once a defendant’s record places him squarely in Williams’s “dangerous” camp, appellate courts will affirm § 922(g)(1) convictions without remand. Second, it affirms sentencing courts’ authority—indeed their duty—to apply the homicide cross-reference when ballistic and circumstantial evidence support it, even absent a separate homicide conviction.

Practitioners should heed two practical lessons: meticulously compile (or contest) the defendant’s full criminal history when mounting Second Amendment challenges, and recognize that every forensic breadcrumb in a firearm case can escalate exposure from a 10-year statutory maximum to effective life-level guidelines. Meeks thus stands as a cautionary tale and a doctrinal waypoint in the ever-evolving landscape of gun-rights litigation and federal sentencing.