Case Explained: United States of America v. Stephen Biviano Zapata

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-18 The eighth-circuit affirmed the district court’s judgment denying Stephen Zapata’s motion to dismiss his indictment for unlawful possession of a firearm as an unlawful user of a controlled substance under 18 U.S.C. § 922(g)(3). The court held that Zapata’s argument that the statute is unconstitutional on its face under the Second Amendment was foreclosed by binding circuit precedent, specifically *United States v. Veasley*, 98 F.4th 906 (8th Cir. 2024). The panel determined that the Supreme Court’s decision in *United States v. Rahimi* did not call this precedent into question, citing *United States v. Deng*, 142 F.4th 1075 (8th Cir. 2025), which rejected similar requests to reconsider *Veasley* post-*Rahimi*. Consequently, the district court’s denial of the motion stands, and Zapata’s conviction and 27-month prison sentence remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.