Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. DEYONTE’ XAVIAN BETTIES

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-22 Docket: 3:25-cr-00019-MCR-2 The eleventh-circuit affirmed the district court’s judgment denying Deyonte’ Xavian Betties’s motion to dismiss his indictment and upholding his conviction and sentence for possessing a machinegun conversion device under 18 U.S.C. § 922(o). The court held that machineguns are not protected by the Second Amendment because they are not weapons in common use for lawful purposes, a standard derived from the Supreme Court’s *Heller* and *Miller* framework as applied in this circuit’s precedent. Relying on its prior-panel decision in *United States v. Alsenat*, 174 F.4th 45 (11th Cir. 2026), which specifically rejected the argument that machinegun conversion devices are “dangerous” or “unusual,” the court found itself bound to reject Betties’s identical constitutional challenge. Consequently, the district court’s denial of the motion to dismiss was correct, and Betties remains subject to his 40-month imprisonment sentence. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.