Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. RODZEBIES JERMINE SMITH

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-06 Docket: 9:25-cr-80102-DMM-1 The Eleventh Circuit affirmed Rodzebies Smith’s conviction for possessing a firearm as a felon in violation of 18 U.S.C. § 922(g)(1), granting the government’s motion for summary affirmance. The court held that Smith’s Second Amendment challenge to the statute is foreclosed by binding circuit precedent, specifically *United States v. Rozier* and *United States v. Dubois*. Applying the standard of review for summary disposition, the court determined that the government’s position was “clearly right as a matter of law” because no substantial question existed regarding the outcome. The court rejected Smith’s argument that the en banc decision in *National Rifle Association v. Bondi* abrogated prior precedent by requiring a new application of the Supreme Court’s history-and-tradition test from *N.Y. State Rifle & Pistol Ass’n v. Bruen* and *United States v. Rahimi*. The panel reasoned that *Bondi* merely reiterated the general methodology for evaluating Second Amendment challenges without explicitly overruling previous decisions, allowing it to coexist with *Dubois*, which confirmed that *Rozier* remains binding precedent regarding felon-in-possession laws. Consequently, the court found that *Dubois* controls the case and bars Smith’s constitutional challenge. The practical consequence is that the district court’s judgment of conviction stands, and Smith’s sentence remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.