United States v. Adams: Reaffirming the Beyond‐Reasonable‐Doubt Standard and the Constitutionality of 18 U.S.C. § 922(g)(1)

Introduction

United States v. Adams is a 2025 decision by the Tenth Circuit Court of Appeals in which the court addressed two critical questions: (1) whether certain prosecutorial remarks in closing argument diluted the constitutional requirement that the government prove guilt beyond a reasonable doubt, and (2) whether 18 U.S.C. § 922(g)(1)—which prohibits a convicted felon from possessing a firearm—is facially or as‐applied unconstitutional under modern Second Amendment jurisprudence. The appellant, Patrick Lee Adams, was convicted in the Western District of Oklahoma of unlawful firearm possession. On appeal, he challenged the prosecutor’s references to “reasonableness” in closing and invoked New York State Rifle & Pistol Ass’n v. Bruen (2022) to contest § 922(g)(1). The Tenth Circuit, in a unanimous panel opinion by Judge Moritz, rejected both challenges and affirmed the conviction.

Summary of the Judgment

The Tenth Circuit affirmed Adams’s conviction, holding (1) that the prosecutor’s isolated references to which narrative was “more reasonable” did not misstate the beyond‐reasonable‐doubt standard nor shift the burden of proof, especially in light of repeated, correct jury instructions; and (2) that § 922(g)(1) remains constitutional post‐Bruen, including as applied to nonviolent felons. The court applied plain‐error review to the unobjected‐to remarks, found no “clear or obvious” error, and determined that any arguable error did not prejudice Adams or undermine confidence in the verdict. On the constitutional challenge, the panel relied on its recent decision in Vincent v. Bondi (2025), reaffirming that there exists a longstanding historical tradition of disarming individuals deemed dangerous—including felons—and that § 922(g)(1) is consistent with this tradition.

Analysis

Precedents Cited

Jackson v. Virginia (1979): Established that criminal convictions must rest on proof beyond a reasonable doubt.
In re Winship (1970): Confirmed the constitutional requirement of proof beyond a reasonable doubt.
United States v. Starks (10th Cir. 2022): Addressed improper prosecutorial statements that conflicted with the presumption of innocence and reasonable‐doubt standard.
Monk v. Zelez (10th Cir. 1990): Found reversible error where the jury received an erroneous definition of “beyond a reasonable doubt.”
United States v. Litchfield (10th Cir. 1992): Upheld conviction despite an Allen charge where the district court twice emphasized the prosecution’s burden of proof.
New York State Rifle & Pistol Ass’n v. Bruen (2022): Introduced the “text, history, and tradition” test for evaluating Second Amendment restrictions.
Vincent v. Bondi (10th Cir. 2025): Confirmed the constitutionality of § 922(g)(1) under Bruen, including its application to nonviolent felons.

Legal Reasoning

1. Plain‐Error Review of Prosecutorial Statements: Adams did not object at trial to the prosecutor’s closing remarks. Under Fed. R. Crim. P. 52(b) and Tenth Circuit precedent, the court applied the four‐part plain‐error test:

Error—Did the prosecutor misstate the law?
Plainness—Was the error “clear or obvious”?
Substantial Rights—Did the error prejudice the defendant?
Discretionary Correction—Would correcting the error “seriously affect the fairness, integrity or public reputation of judicial proceedings”?

The court held that although the prosecutor twice used language evoking “reasonableness,” these comments were contextually minor and did not contradict the district court’s repeated, correct instructions on proof beyond a reasonable doubt. Citing United States v. Sierra‐Ledesma and United States v. Bland, the panel emphasized the presumption that juries follow instructions and found no “so clear or obvious” misstatement like those in Monk v. Zelez or Starks. Even if the remarks were technically improper, they did not undermine confidence in the verdict given the strength of the evidence and the curative instruction.

2. Second Amendment Challenge to § 922(g)(1): Adams argued under Bruen that there is no historical analogue for disarming nonviolent felons. The court reaffirmed its prior ruling in Vincent v. Bondi, explaining that:

The government bears the burden of showing that a firearm restriction is consistent with the nation’s historical tradition of firearm regulation.
Historical records from the founding era through the late 19th century show widespread disarmament of persons convicted of serious crimes, including nonviolent felonies.
Section 922(g)(1) is a direct descendant of these longstanding traditions and thus passes constitutional scrutiny under the text‐history‐tradition test.

Impact on Future Cases

The Adams decision underscores two enduring principles:

Prosecutorial comments that merely invite jurors to apply common‐sense reasonableness, without undermining the formal reasonable‐doubt instruction, will rarely warrant reversal under plain‐error review.
Courts will continue to uphold § 922(g)(1) post‐Bruen, finding a robust historical tradition of disarming felons—even nonviolent ones—thereby limiting successful Second Amendment challenges to this statute.

Lower courts in the Tenth Circuit can cite Adams for its persuasive authority that procedural safeguards (correct jury instructions, Allen charges) cure minor argumentative excesses, and that § 922(g)(1) remains valid under modern constitutional scrutiny.

Complex Concepts Simplified

Plain‐Error Review: A four‐step test applied when a defendant fails to object at trial: (1) Was there an error? (2) Was it clear and obvious? (3) Did it affect the outcome? (4) Should the court correct it to preserve judicial integrity?
Beyond a Reasonable Doubt: The highest criminal standard of proof. It requires jurors to be “firmly convinced” of guilt; jurors must acquit if they have any real, common‐sense doubt.
Allen Charge: A supplemental jury instruction urging jurors in deadlock to re‐examine their views and try to reach unanimity without abandoning honest convictions.
Text‐History‐Tradition Test (Bruen): A two‐step framework for Second Amendment challenges: first, decide if the conduct falls within the Amendment’s text; second, determine whether the regulation is consistent with the historical tradition of firearm regulation.

Conclusion

United States v. Adams reinforces the principle that isolated prosecutorial appeals to “reasonableness” do not dilute the constitutional requirement of proof beyond a reasonable doubt when the trial court provides accurate and emphatic instructions. It also confirms that § 922(g)(1) survives modern Second Amendment scrutiny, cementing the long‐standing practice of disarming convicted felons. This decision will guide litigants and courts in evaluating both closing‐argument challenges and constitutional attacks on federal firearm disability statutes.