Introduction

In United States v. Samuels, No. 24-6018 (10th Cir. Mar. 27, 2025), the Tenth Circuit affirmed a district court’s revocation of supervised release and reimposition of a standard condition prohibiting firearm possession. Defendant–Appellant Lawrence Samuels, Jr., argued that the condition violates the Second Amendment under the Supreme Court’s decisions in New York State Rifle & Pistol Association v. Bruen (2022) and United States v. Rahimi (2024). The panel, however, held that it was bound by the Tenth Circuit’s recent published decision in Vincent v. Bondi (2025), which reaffirmed the constitutionality of longstanding felon firearm prohibitions post-Bruen and after remand in light of Rahimi.

The case thus squarely presents how Bruen’s text-and-history framework and Rahimi’s clarification interact with supervised-release conditions that mirror 18 U.S.C. § 922(g)(1) (the felon-in-possession prohibition). The court’s disposition confirms that, at least within the Tenth Circuit, such conditions remain constitutional and may serve as valid grounds for revocation.

Case Background

Mr. Samuels pled guilty in 2004 to possession with intent to distribute a controlled substance (21 U.S.C. § 841(a)(1), (b)(1)(B)(iii)). After a commutation, he began supervised release in May 2018. One standard condition barred him from possessing a firearm, destructive device, or other dangerous weapon. In September 2022, during a traffic stop in Texas, officers discovered a handgun hidden in a sock in the engine bay of a rental car Mr. Samuels was driving. His probation officer petitioned to revoke supervised release, alleging violations of the mandatory “no new crime” condition and the “no firearms” condition (as well as an undisputed travel violation).

The district court initially revoked his supervised release, applying a “sole‑occupancy” standard to find constructive possession of the gun, and imposed 24 months’ imprisonment and 36 months’ supervised release, again including the “no firearms” condition. On appeal, the Tenth Circuit vacated and remanded because the district court applied the wrong constructive‑possession standard; given the rental context, the correct “joint occupancy” standard applied. See United States v. Samuels, No. 23-6000, 2023 WL 8596457 (10th Cir. Dec. 12, 2023).

On remand, the district court found constructive possession under the joint‑occupancy standard and imposed a sentence of time served plus two years of supervised release with the same no‑firearms condition. In this appeal, Mr. Samuels did not challenge the constructive‑possession finding; instead, he argued that the Second Amendment rendered the firearm condition unconstitutional and therefore could not support revocation or reimposition.

Summary of the Opinion

The Tenth Circuit affirmed. Reviewing for plain error (because Mr. Samuels did not object to the condition below) and de novo on legal questions related to revocation, the panel held that its published precedent in Vincent v. Bondi, 127 F.4th 1263 (10th Cir. 2025), controls. Vincent reaffirmed—after the Supreme Court’s remand in light of Rahimi—that Bruen does not invalidate the Tenth Circuit’s longstanding recognition of the constitutionality of prohibitions on firearm possession by convicted felons.

Because prohibitions on felon firearm possession remain constitutional under binding circuit law, the supervised‑release condition barring Mr. Samuels from possessing a firearm is constitutional. Accordingly, there was no error—let alone plain error—in revoking supervised release based on that condition or in reimposing it.

Analysis

Precedents Cited and Their Role

• United States v. Mike, 632 F.3d 686 (10th Cir. 2011): The court invoked Mike for two propositions: the plain‑error standard of review when a defendant fails to object to a supervised‑release condition in the district court, and the principle that such conditions must comport with the Constitution. Mike framed the analytic lens—Mr. Samuels had to demonstrate a clear legal error affecting substantial rights—a difficult hurdle where settled circuit precedent runs the other way.
• United States v. Williams, 106 F.4th 1040 (10th Cir. 2024): Cited for the proposition that legal questions relating to the revocation of supervised release are reviewed de novo, this confirms the court’s willingness to consider constitutional arguments afresh while still applying plain‑error constraints to unpreserved objections.
• United States v. McCane, 573 F.3d 1037 (10th Cir. 2009): Post‑Heller, McCane upheld the constitutionality of felon‑in‑possession prohibitions. McCane forms the backbone of the Tenth Circuit’s felon‑firearm jurisprudence, which later decisions evaluate in light of Bruen and Rahimi.
• New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022): Bruen adopted a text‑and‑history methodology for Second Amendment challenges. The key question in later cases has been whether Bruen undermined prior circuit precedent on felon firearm bans. The Tenth Circuit has repeatedly answered no.
• United States v. Rahimi, 602 U.S. 680 (2024): Rahimi upheld § 922(g)(8) (disarmament while under certain domestic‑violence restraining orders), clarifying how Bruen’s history‑and‑tradition framework applies to status‑based firearm restrictions. After Rahimi, the Supreme Court vacated and remanded certain lower‑court decisions for reconsideration, including Vincent.
• Vincent v. Garland, 80 F.4th 1197 (10th Cir. 2024), vacated and remanded sub nom. Vincent v. Garland, 144 S. Ct. 2708 (2024); readopted as Vincent v. Bondi, 127 F.4th 1263 (10th Cir. 2025): On remand from the Supreme Court post‑Rahimi, the Tenth Circuit readopted its earlier opinion, concluding that nothing in Rahimi undermined its reasoning that longstanding felon disarmament laws remain constitutional under Bruen’s test. Vincent is the binding, published authority that squarely forecloses Mr. Samuels’s arguments.
• United States v. Swan, 91 F.4th 1052 (10th Cir. 2024): Noted to reinforce that the Tenth Circuit remains bound by its precedent on felon firearm prohibitions in the post‑Bruen landscape.
• United States v. Samuels, No. 23‑6000, 2023 WL 8596457 (10th Cir. Dec. 12, 2023): The court’s prior decision in Mr. Samuels’s own case clarified constructive‑possession standards (joint‑occupancy vs. sole‑occupancy) for vehicles like rental cars. Although constructive possession was not contested in this appeal, that earlier ruling framed the remand and subsequent revocation.

Legal Reasoning

The court’s reasoning proceeded in two straightforward steps, shaped by the posture of the case:

• Standard of review constrained the outcome. Because Mr. Samuels did not object to the no‑firearms condition when it was reimposed on remand, the Tenth Circuit reviewed for plain error. Under this demanding standard, an error must be clear or obvious under current law and affect substantial rights, and the court must also decide that the error seriously affects the fairness, integrity, or public reputation of judicial proceedings (Mike). Where binding circuit precedent holds the opposite of the appellant’s position, demonstrating “plain” error is virtually impossible.
• Binding circuit law forecloses the Second Amendment challenge. The panel explained that Vincent (readopted as Vincent v. Bondi after the Supreme Court’s remand) reaffirms that Bruen does not invalidate longstanding prohibitions on firearm possession by convicted felons. Rahimi did not undermine that conclusion. Accordingly, both (a) the revocation premised on violation of the no‑firearms condition and (b) the reimposition of that condition survive Second Amendment scrutiny. With no underlying constitutional error, Mr. Samuels’s request for immediate termination of supervised release necessarily fails.

The court emphasized that it is bound by Vincent, and Mr. Samuels expressly acknowledged that his arguments were made to preserve issues for potential en banc or Supreme Court review if Vincent were reaffirmed.

Impact and Implications

Samuels reinforces several important points for practitioners and courts within the Tenth Circuit:

• Supervised‑release gun conditions for felons remain constitutional. Conditions mirroring § 922(g)(1) continue to be valid under the Second Amendment after Bruen and Rahimi. Revocations premised on such conditions, and reimposed terms containing them, are secure against facial constitutional attack in this circuit.
• Challenges must grapple with Vincent. Absent intervening en banc or Supreme Court authority, district courts and panels are bound by Vincent v. Bondi. Defense counsel should expect constitutional challenges to § 922(g)(1)-like conditions to be rejected on the basis of Vincent and McCane.
• Preservation matters. Failure to object to a condition as unconstitutional at sentencing or on reimposition will trigger plain‑error review, further narrowing the path to relief. Timely, specific objections are essential if a litigant intends to press a Second Amendment challenge.
• Constructive possession standards clarified by the earlier appeal remain relevant. Although not decided here, the court’s prior remand underscores that, in revocation proceedings, constructive‑possession determinations in shared or temporary vehicle contexts must apply the joint‑occupancy standard. That doctrinal refinement may influence future revocation hearings that turn on similar facts.
• Scope of this holding. Samuels addresses felon firearm prohibitions in the supervised‑release context and does not disturb the possibility that other, more unusual firearm‑related conditions might require individualized justification or could be challenged on other grounds (for example, statutory reasonableness under 18 U.S.C. § 3583(d)). But for the standard no‑firearms condition applicable to felons, the constitutional question is settled in this circuit.
• Nonprecedential disposition; precedential predicate. While this Order and Judgment is nonprecedential (except for law‑of‑the‑case and related doctrines), its reasoning relies on Vincent v. Bondi, which is published and binding circuit law. Practically, the rule applied here is the circuit’s rule.

Complex Concepts Simplified

• Supervised Release and Conditions: After imprisonment, many federal defendants serve a term of supervised release subject to conditions (e.g., law‑abiding behavior, reporting, no firearms). Violating a condition can lead to revocation and additional sanctions.
• Constructive Possession: A person can “possess” something without physically holding it if they have knowledge of it and the ability and intent to exercise control over it. In shared or temporary‑use contexts (like a rental car), courts use a “joint‑occupancy” standard that requires additional links connecting the defendant to the item beyond mere proximity.
• Plain‑Error Review: If a party fails to object in the trial court, the appellate court applies a four‑part test: (1) there was an error; (2) it was “plain” (clear under current law); (3) it affected substantial rights (usually prejudicial); and (4) it seriously affected the fairness, integrity, or public reputation of judicial proceedings. Failing any prong defeats relief.
• Bruen’s Text‑and‑History Test: Courts first ask whether the Second Amendment’s text covers the person’s conduct. If so, the government must justify its regulation by pointing to a historical tradition consistent with the regulation. Bruen replaced tiers of scrutiny with this historical inquiry.
• Rahimi’s Clarification: Rahimi applied Bruen’s framework and upheld a status‑based disarmament provision, emphasizing the longstanding tradition of disarming individuals found to pose a credible threat. It did not cast doubt on felon disarmament laws.
• Felon‑in‑Possession Prohibition (§ 922(g)(1)) vs. Supervised‑Release Conditions: Section 922(g)(1) makes it a crime for felons to possess firearms. Supervised‑release conditions often mirror this prohibition. Both must comport with the Constitution, but case law upholding § 922(g)(1) strongly supports the validity of the parallel supervised‑release condition.
• Precedential Force: A published circuit opinion (like Vincent v. Bondi) binds later panels. A nonprecedential “Order and Judgment” (like Samuels) does not bind future panels, but when it applies binding precedent, it is a reliable indicator of how the circuit will handle similar disputes.

Conclusion

United States v. Samuels confirms that, within the Tenth Circuit, a standard supervised‑release condition prohibiting firearm possession by a convicted felon remains constitutional under the Second Amendment after Bruen and Rahimi. Anchored in the binding authority of Vincent v. Bondi and the circuit’s longstanding precedent in McCane, the panel rejected an attempt to invalidate revocation and reimposition of the condition. The decision underscores two practical lessons: preservation of constitutional challenges at sentencing is critical, and felon‑in‑possession restrictions—whether codified in § 922(g)(1) or implemented as supervised‑release conditions—continue to stand on firm constitutional ground in this circuit. While the opinion is nonprecedential, it faithfully applies controlling law and provides a clear roadmap for future Second Amendment challenges to standard supervised‑release firearm conditions.